2023 (10) TMI 208

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.... -<br>Income Tax<br>Honourable Mr.Justice Mohammed Shaffiq For the Petitioner in all petitions : Mr.Ashokapathy for M/s Pass Associates For the Respondent in all petitions : Mr.A.P.Srinivas, Senior Standing Counsel COMMON ORDER The three writ petitions are filed challenging the impugned notices for the assessment years 2015-16, 2016-17 and 2017-18. 2. The short question that arises ....

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....profit percentage of 3 % (mistakenly mentioned as 5%) offered by others in the same line of business. The assessee vide letter dated 05.04.2019 retracted the above statement recorded on 08.03.2019. 3.2. On the basis of the said statement, notices were issued under Section 148 of the IT Act on 31.03.2021, to which, the petitioner submitted its objection interalia raising the issue of jurisdictio....

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....t it is conclusive and it is open to the person who made the admission to show that it is incorrect and that the assessee should be given a proper opportunity to show that the books of accounts do not correctly disclose the correct state of facts, vide decision of the Apex Court in Pullangode Rubber Produce Co. Ltd. v. State of Kerala [(1973) 91 I.T.R. 18]; (ii) In contradistinction to th....

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....s Court in W.P.Nos.21919 to 21921 of 2018 dated 25.02.2019 reported in (2019) 417 ITR 0050 (Mad). It was further submitted that there is a circular which would also indicate that the assessing authority has been directed to gather evidence and to avoid admission of undisclosed income under coercion. 6. To the contrary, it was submitted by the learned counsel for the respondent that the petition....