2021 (10) TMI 1265

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....Shehnaz V. Bharucha for Respondent   P.C. : 1. Petitioner is impugning an order dated 30th March 2021 passed under Section 201(1) and 201(1A) of the Income Tax Act, 1961 (the said Act) for A.Y.-2016-2017 on various grounds including that the order is contrary to the principles of natural justice, beyond period of limitation, it is arbitrary and unreasonable etc. 2. Petitioner is wholly own....

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....Act, verification of details furnished in form No.15CA in view of non deduction / lower deduction of tax at source . This is followed by notices dated 18th February 2021, 4th March 2021, 9th March 2021 and 16th March 2021 under Section 201 of the Act. Petitioner replied to these show cause notices by its letters dated 22nd February 2021, 10th March 2021, 18th March 2021 and a comprehensive reply d....

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....d 18th March 2021. The impugned order, however, is totally silent about the reply dated 10th March 2021 and the comprehensive reply dated 26th March 2021. Not only respondent no.1 has failed to deal with these replies in the impugned order there is not even a reference to the said replies. Moreover, in the impugned order, respondent no.1 states that petitioner is not an independent person and its ....

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....ing into the merits of the matters but does not answer the moot point as to why all the replies given by petitioner to show cause notices issued have not been considered and dealt with in the impugned order. Ms Bharucha also referred to the affidavit in reply and submitted that petitioner was dependent PE for PDR Solutions UAE and thus there was dependent PE in India and remittance of tax in India....