2023 (3) TMI 862

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....tha, Advocate JUDGMENT MANMOHAN, J: 1. Present writ petition has been filed challenging the notice dated 18th May, 2022 issued under Section 148A(b) of the Income Tax Act, 1961 (for short 'Act') and the order dated 26th July, 2022 passed under Section 148A(d) of the Act for the Assessment Year 2014-15. 2. Learned counsel for the Petitioner states that the impugned order is arbitrary and cry....

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.... it has been found that M/s Seema Enterprises is not involved in any real business and hence the contention of the learned counsel for the petitioner that it made payments in the course of business was not accepted. Further, in the impugned order the Assessing Officer has specifically recorded that the proprietor Smt. Seema Gupta has accepted that her firm was not engaged in real business activiti....