TaxTMI 
TaxTMI 
2023 (8) TMI 1084
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....dade. For the Respondents : Mr. Suresh Kumar. P.C. : 1. Petitioner is impugning a notice dated 31st March 2021 issued under Section 148 of the Income Tax Act, 1961 (the Act) and the order dated 11th March 2022 rejecting petitioner's objections to re-open. 2. Petitioner is an asset reconstruction company. Petitioner had filed return of income for Assessment Year 2017-18 on 26th October 2017 ....
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.... Act issuing notice under Section 148 of the Act by A.O. is absent. The reason for petitioner to state this is because in the approval copy under Section 151 of the Act made available to petitioner states "Reasons to Believe - As per Annexure." But in the annexure it is only blank page. In ground (N) to the petition, petitioner has alleged as under : N. That the impugned notice dated 31.03.2021 ....
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....f the reasons was provided to the petitioner vide later dated 15.11.2021. 5. Therefore, there is no denial of the fact that the annexure did not contain any reasons. On this ground alone in our view the impugned notice and the order on objections have to be quashed and set aside. 6. During the hearing Mr. Suresh Kumar tendered photocopy of the Form for recording reasons for initiating proceedin....