2021 (12) TMI 1083

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....by the appellant challenging a notice issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as "the Act") dated 11.11.2009, and the proceedings of the respondent dated 01.12.2010, by which the objections raised by the appellant for the reopening was rejected. 3.The principle ground on which the writ petition was filed is by contending that the reopening is a case of change of opinion and the respondent has no jurisdiction to reopen the assessment for the reasons set out in the proceedings dated 23.04.2010. 4.The learned Single Bench had dismissed the writ petition and while doing so, has made an observation that prima facie, the reopening appears to be in order. 5.There were three issues, which were subject ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....at the appellant wanted extension of time for the respondent to pass appropriate orders, since the appellant was in the process of collating details of all pending litigations, which were initiated/pending prior to the acquisition of the appellant company by Ms/.Dhanuka Laboratories Ltd. This petition was considered and the learned Single Bench extended the time and subsequently, the appellant had filed this appeal before this Court and the appeal was not numbered immediately because, change of cause title has to be ordered and when the appeal was in the process of being numbered, it appears that the appellant had made an oral mention before the learned Single Bench for further extension of time. From the affidavit filed in support of the M....