2022 (4) TMI 43

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....ra, Assistant Solicitor General, Mrs. Naushina Afreen Ali, Advocate with Mr. Ajay Kumrani, Advocate on behalf of Mr. Amit Chaudhary, Advocate ORDER Heard. Learned counsel for petitioner would submit that notice under Section 148 of the Income Tax Act, 1961 (henceforth 'the Act of 1961') is served upon petitioner with respect to assessment year 2014-15 after lapse of period of four....

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....reasons to believe recorded by Assessing Officer only mentions that information available with department is that petitioner is involved in obtaining bogus bills from a paper shell company of Kolkata, but name of company from whom petitioner has obtained bogus bills has not been specifically mentioned by Assessing Officer. If reasons are recorded by Assessing Officer based on certain information, ....

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....on of this petition, some interim protection may be granted to the petitioner. In support of his submissions, he places reliance on decision in case of Sound Casting Pvt. Ltd. Vs. DCIT reported in (2012) 250 CTR 119 & Micro Links Pvt. Ltd. Vs. ACIT reported in 2017 (2) TMI 337 Gujarat. Learned counsel for respondent Nos.2 to 4 vehemently opposes submissions of learned counsel for petitioner and....

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....rly contents of assessment order under Section 143 (3) of the Act of 1961 where total income of petitioner assessee has been accepted by Assessing Officer, as also contents of reasons to believe recorded by Assessing Officer, determining total loss at Rs. 1,96,62,420/-, and further considering that name of paper shell company has not been specifically mentioned by Assessing Officer in the reasons ....