2024 (12) TMI 716

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....#39;BLE MR. JUSTICE TUSHAR RAO GEDELA For the Petitioner Through: Dr. Shashwat Bajpai, Advocate. For the Respondent Through: Mr. Ruchir Bhatia, SSC with Mr. Anant Mann, JSC, Mr. Abhishek Anand, Advocates. VIBHU BAKHRU, J. (ORAL) 1. The petitioner, Jackson Square Aviation Ireland Limited (hereafter Assessee), has filed the present petition, inter alia, impugning the Final Assessment Ord....

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....e AO subsequently passed the Draft Assessment Order proposing an addition of Rs. 499,99,19,251/- on account of treating lease rentals received by the Assessee from leasing of aircraft as interest income and proposed penalty as well. 3. Aggrieved by the Draft Assessment Order dated 31.03.2024 passed under Section 144C (1) of the Act, the Assessee filed its objections in Form No. 35A on 29.04.202....

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....ts objections disposed of by the DRP by passing the impugned Final Assessment Order. The Assessee also contends that no real time alert was sent to its registered e-mail Id. 5. The Assessee relies upon the judgments of this Court in Fiberhome India Private Limited vs. National E-Assessment Centre in W.P.(C) 11609 of 2021 dated 15.12.2021, Pepsico India Holding (P.) Ltd. vs. Assessment Unit Inco....

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....d within time. 6. Learned counsel appearing for the Revenue submits that a notice dated 18.04.2024 was communicated to the Assessee informing it that a Draft Assessment Order under Section 144 (C) (1) of the Act was passed in its case. He also contends that notwithstanding the aforesaid communication, an e-mail dated 09.05.2024 regarding the passing of Draft Assessment Order was also issued. ....