2024 (2) TMI 162

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.... filed today, is taken on record. 2. Heard Shri Suyash Agarwal, learned counsel for the petitioner and Shri Manu Ghildyal, learned counsel for the Revenue. 3. Challenge has been raised to the reassessment proceedings initiated against the petitioner under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the 'Act, 1961') for the Assessment Year 2016-17, vide notice date....

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.... report, income tax return, purchases ledger account, ledger account of M/s Bait-Al-Tamurat and bank statement. At the stage of rejecting that reply, by means of order passed under Section 148A(d) of the Act, 1961, a new ground of purchases having been made outside the books of accounts, has been raised. 6. Thus, it has been submitted, there is no cogent material to proceed against the petitioner....

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....023 (Annexure-4 to the writ petition) does not establish that either the purchases made by the petitioner from M/s Bait-Al-Tamurat during the financial year 2015-16 valued at Rs. 2,68,88,124/- were paid through banking channel or that no purchases were made by the petitioner from such seller. 9. What may have been the total quantum of purchases made by the petitioner from M/s Bait-Al-Tamurat and ....