2022 (12) TMI 1093

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....oner challenges the notice under Section 148A(b) dated 02nd June, 2022. Apart from this, the Petitioner also challenges the order dated 08th July, 2022 passed by the Commissioner of Income Tax (International Taxation-2), Mumbai, in purported exercise of powers under Section 127 of the Act. 2. Briefly stated the material facts are as under: In the initial round of litigation the Petitioner had fled Writ Petition bearing No. 4980 of 2022, whereby the Petitioner inter alia had challenged notice under Section 148 of the Act, dated 13th June, 2021 issued by the concerned officer at Bombay. This writ petition came to be decided in a batch of petitions in Tata Communication Services Ltd. Vs. ACIT and the impugned notice was quashed. Subseque....

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....on was raised by the Respondents that Delhi High Court had no jurisdiction to decide the legality and validity of a notice issued by Respondent No. 1 under Section 148 of the Act, keeping in view the fact that the initial notice under Section 148 of the Act had been challenged by the Petitioner before the Bombay High Court. 4. The Delhi High Court was of the opinion that since the Petitioner had initially approached the Bombay High Court, the averments made in the said writ petition would have a material bearing and accordingly, directed to place on record a copy of the writ petition filed by it before the Bombay High Court, challenging the initial notice under Section 148 of the Act dated 30th June, 2021. Subsequently, on the next date ....