2022 (12) TMI 801

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....RABLE MS. JUSTICE SONIA GOKANI 1. Draft amendment is allowed. To be carried out forthwith. 2. The petitioner by way of the present petition under Article 226 of the Constitution of India challenges issuance of notice by the respondent under Section 148A(d) of the Income Tax Act, 1961 ('the IT Act' hereinafter) dated 27.4.2022 proposing to issue the notice under Section 148 of the IT Act for the....

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....e hands of the donor himself the source of the gift is being assessed therefore, the assessment in the hands of the donee petitioner simultaneously is not acceptable. It is his case that the petitioner has received the gift from his father, whose capital already on 31.12.2017 stood to nearly Rs.188 Crore. He has further urged relying on the decision of the Commissioner of Income Tax vs. Kelvinator....