2019 (6) TMI 1641

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....or Respondent : Mr.G.Rajagopalan Additional Solicitor General Assisted by Mr.Karthik Ranganathan Senior Standing Counsel for Income Tax Department ORDER The show-cause notice seeking explanation / reply as to why the Assessment of AY-2014-2015 made under Section 143 (3) read with Section 92 CA of the Income Tax Act, (in short "Act") dated 31.12.2016, should not be treated as erroneous and prejud....

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....rn filed by the petitioner and passed orders on 31.12.2016. 3. In the year 2017, notices were issued to the petitioner's shareholders viz., Cognizant (Mauritius) Limited and Cognizant Technology Solutions Corporation, United States, on the ground of over valuation of shares. The shareholders of the petitioner have challenged the Draft Assessment Orders in W.P.Nos.1244 & 1245 of 2018. 4. Mr.G....

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....garded as dividend and the impugned notice has been issued in a hurried manner without providing sufficient time to the petitioner to send a reply and hence, it is liable to be set-aside. 5. In reply, Mr.G.Rajagopalan, learned Additional Solicitor General on behalf of the Revenue would argue that the order impugned in this Writ Petition is only a show-cause notice and the petitioner has not ....