2023 (5) TMI 915

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....HI(9771) FOR THE PETITIONER(S) NO. 1 DS AFF.NOT FILED (N) FOR THE RESPONDENT(S) NO. 3 MR NIKUNT K RAVAL(5558) FOR THE RESPONDENT(S) NO. 1 MR.VARUN K.PATEL(3802) FOR THE RESPONDENT(S) NO. 2 ORDER (PER : HONOURABLE THE CHIEF JUSTICE MS. JUSTICE SONIA GOKANI) ORDER IN SPECIAL CIVIL APPLICATION NO. 11846 OF 2022 Special Civil Application No. 11846 of 2022 is under challenged where, this ....

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....since, the petitioner has failed to disclose the certain vital details. On the basis of information received from the DDIT ( Investigation ) Unit 1(1), Ahmedabad through Insight portal, the Suspicious Transaction Report (STR) was generated by Finance Intelligence Unit of India in case of the assessee. The assessing officer had observed that the cash withdrawals of Rs.18.00 crores reported in STR a....

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....l, learned Sr.Standing Counsel for the respondent. It is only for the limited purpose of the grant of interim relief, this matter is being heard. We noticed that though the allegation is of petitioner being Shell Company, for the AY.2013-14 2014-15, the notice for reassessment had been dropped. Prima facie, there does not appear to be a case of Shell Company However, what is objected by the Asses....

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....amining by Assessing Officer, though the books of account and other material had been placed, has continued the proceedings and issued the notice u/s. 148 of the I.T.Act. Since there was a scope of Assessing Officer for the scrutiny assessment at the time of scrutiny assessment, which is still in the grey area as to whether the aspect of cash withdrawal, he could not be noticed because of want of....