2023 (5) TMI 474

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....the petitioner seeking interim relief]. 2. Issue notice. 2.1 Mr Vipul Agarwal, senior standing counsel, who appears on behalf of the respondents/revenue, accepts notice. 3. Mr Agarwal says that in view of the order that we propose to pass, counter-affidavit is not required to be filed and he will argue the matter based on the material available on court record. 4. With the consent of parties, the writ petition is taken up for final hearing and disposal at this stage itself. 5. This writ petition is directed against the order dated 31.07.2022 passed under Section 148A(d) and the consequential notice of even date, i.e., 31.07.2022, issued under Section 148 of the Income Tax Act, 1961 [in short, "the Act"]. 6. Besides this, c....

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....itioner/assessee, in the notice issued under Section 148A(b) of the Act. 14. Thus, out of Rs. 2,70,00,000/-, the petitioner/assessee asserted in the said reply that Rs. 35,00,000/- was received from unrelated parties, and the balance of Rs. 2,35,00,000/- was received from related parties. 15. The unrelated parties to which the petitioner made reference are the following: (i) Como Info Solutions Pvt Ltd; (ii) Karda Traders Pvt Ltd; (iii) Next Generation Exim Pvt Ltd. 16. Strangely, the AO while noticing the reply filed by the petitioner, has adverted to the amount said to have been repaid by the petitioner to the Jain brothers. 17. This aspect of the matter emerges by reading together both paragraph 8.1....