2022 (5) TMI 52

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....For the Respondent : Asstt.S.G.I. ORDER Heard Mr. R. Goenka, learned counsel for the petitioner, who submits that the procedure adopted by the respondents in re-opening the case of the petitioner under Section 147 of the Income Tax Act, 1961 is illegal and accordingly, should be set aside. 2. The petitioner's case is that the petitioner was issued a notice dated 26.03.2021 under Section 1....

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....any income chargeable to tax has escaped assessment. He also submits that the respondent authority had reason to believe that the petitioner had been the beneficiary of a loan amount of Rs. 38,91,000/-, allegedly received from M/s Vishal Metal & Mining Corporation. However, the petitioner in his objections dated 17.07.2021 submitted to the respondent authorities had explained that no loan had been....

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.... Act has been rejected by the respondents vide Letter dated 17.09.2021. 5. Mr. S. Sarma, appearing on behalf of the Income Tax Department submits that the final decision with respect to the proceedings under Section 148 of the IT has not been made by the respondents till date and as such, the present case is a pre-mature. He submits that even after a decision is passed by the respondent with re....