2022 (2) TMI 537

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....Kumar, for the Respondents P.C.: Petitioner is impugning notice dated 18th March, 2013 issued under section 148 of the Income Tax Act, 1961 by which Respondent No. 1 has informed Petitioner that he has reason to believe that Petitioner's income chargeable to tax for assessment year 2008-2009 has escaped assessment within the meaning of section 147 of the Act. We have considered the reaso....

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....ion relevant to assessment year 1997-98 to 2001-02 can be carried forward and set off against any other heads of income except income under the head business or profession for more than eight first computed. Similarly, brought forward unabsorbed depreciation allowance for and upto A.Y. 1996-97, which could not be set off upto A.Y.1996-97, shall be carried forward for set off against income under a....

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....-1999 4,36,55,712 1999-2000 13,74,80,406 2000-2001 12,36,82,506 Total 30,48,18,624 In view of the above, I have reason to believe that income chargeable to tax as enumerated herein above, has escaped assessment within the meaning of section 147 read with proviso thereto by reason of failure on the part of the assessee to disclose fully and truly all material facts nec....

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....ourt in General Motors India (P) Ltd. vs. Deputy Commissioner of Income Tax [2012] 25 taxmann.com 364 (Guj.). This has been followed by this Court in various matters, one of which is Pr. Commissioner of Income Tax, Central-2 vs. Supreme Petrochem Ltd. ITA.No. 661 of 2017 Dt.07-06-2019 in the order 7^th June, 2019. When we are pointed this out to Mr. Suresh Kumar, Mr. Suresh Kumar in fairness agree....