2022 (3) TMI 1290

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ax<br>HON&#39;BLE MR. JUSTICE MANMOHAN AND HON&#39;BLE MR. JUSTICE DINESH KUMAR SHARMA Petitioner Through Mr. Ajay Vohra, Sr. Advocate with Dr. Shashwat Bajpai and Mr. Vishal Aggarwal, Advs. Respondents Through Mr. Ruchir Bhatia, Advocate J U D G M E N T MANMOHAN, J (Oral): 1. Present writ petitions have been filed challenging the notices dated 30th March, 2021 issued under Section 148 of the....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... offered to tax by the assessee. It is further stated in the impugned order that the plea of the petitioners'-assessee is covered under Para 1(B)(iii)(c) of the CBDT instruction regarding selection of potential cases for issue of notice under Section 148 of the Act issued vide F. No. 225/40/2021/ITA-II dated 15th March, 2021. 4. Learned senior counsel for the Petitioners submits that the impugned....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....med exemption and therefore, the issue will have to be examined during the re-assessment proceedings. 7. In the present cases, the issue of dividend income as well as long term capital gain on the sale of shares requires a detailed consideration. 8. Further, in the present cases, Section 148 notices have been issued within four years from the end of the relevant Assessment Years. Also no scrutin....