2024 (7) TMI 1095

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.... counsel Mr. Varun Patel for the Respondent - Assessing Officer. 1.1 Rule, returnable forthwith. Learned advocate Mr. Varun Patel waives service of notice of Rule on behalf of the respondent. 1.2 Having regard to the controversy in narrow compass, with the consent of learned advocates for the respective parties, the matter is taken up for final hearing. 2. By this petition under Article 226 of the Constitution of India, the petitioner has challenged notice under Section 148 of the Income Tax Act, 1961 (for short 'the Act') issued on 03rd July, 2021 for the Assessment Year 2015-16 beyond the period of four years. 3. The petitioner filed return of income for A.Y. 2015-16 on 23rd September, 2015 and claimed TDS credit of Rs. 19,24,879/-. T....

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....me of the petitioner company and even interest advice was also issued in the name of the petitioner company after deducting the TDS. 3.3 It was, therefore, explained that the petitioner had not considered TDS credit corresponding to interest income which was transferred to Salasar Agropanel Pvt. Ltd. The petitioner also placed on record acknowledgment of return of income filed by the said company with computation of income and ledger of interest income on security deposit. 4. After a period of four years, the impugned notice under Section 148 of the Act was issued. The petitioner sought reasons recorded for re-opening which was supplied to the petitioner on 03rd July, 2021 which are reproduced hereunder:- "1. Brief details of the assess....