2022 (3) TMI 1414

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....gh, ASG a/w Mr. Sham V. Walve ORDER P.C.: 1. The pleadings in the petition are complete and therefore we decided to consider the petition finally at this stage itself. 2. Petitioner has approached this court aggrieved by a notice dated 31st March, 2021 issued under Section 148 of the Income Tax Act, 1961 (the Act) where the Jurisdictional Assessing Officer (JAO) has asserted that he has reason....

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.... Sr. No. Source of PAN Source of PAN Name Information F.Y. Information Type Information Value 1 AABCR3382E RAIMALADITYA TEXTILE PRIVATE LIMITED 2012-13 Loan Taken 40,88,06,800/- 1. As the above mentioned bogus entities managed, controlled and operated by M/s. RAIMALADITYA TEXTILE PRIVATE LIMITED for providing bogus accommodation entries, hence, all the transactions entered int....

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....fore has escaped assessment. 4. Learned ASG submitted that there was a mistake. If that was a mistake that could certainly not be the reason to believe that petitioner's income has escaped assessment. We further note that approval under Section 151 of the Act also has been given on the same reasons, which would also indicate total non application of mind by not only the JAO but also by the Revenu....