TaxTMI 
TaxTMI 
2023 (4) TMI 1383
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....er seeking interim relief] 2. Issue notice. 2.1 Mr Sunil Agarwal, senior standing counsel, accepts notice on behalf of the respondents/revenue. 3. In view of the directions that we propose to pass, Mr Agarwal says that a counter-affidavit is not required to be filed and he will argue based on the record presently available with the court. Therefore, with the consent of the counsels for the parties, the writ petition is taken up for final hearing and disposal, at this stage itself. 4. This writ petition is directed against the notice dated 17.03.2023 issued under Section 148A(b) of the Income Tax Act, 1961 [in short, "the Act"]. 4.1 Besides this, challenge is also laid to the order dated 31.03.2023 passed under Section 148A(d)....
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....ce issued under Section 148A(b) of the Act. The petitioner sought time to file a reply till 05.04.2023. 9. The record indicates that a fresh notice under Section 148A(b) of the Act was issued by the AO on 25.03.2023, wherein the petitioner was accorded time to file a reply to the notice on or before 27.03.2023. 9.1 Apart from this, the AO extended the time to file a reply vis-a-vis the notice dated 17.03.2023. The AO indicated that reply could be filed "before or on 27.03.2023 by 11 AM". 9.2 The AO in this notice also adverted to the fact that limitation qua the petitioner was expiring on 31.03.2023. 10. Concededly, the petitioner was not able to file the reply within the time allocated by the AO. It appears that the time given ....
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...., Gnaga-2, Vasant Kunj, New Delhi at Rs. 2,51,00,000/-. Further, it is quite evident from the contents of the mail that at least Rs. 1,00,00,000/- was paid in cash to the owner of the property (assessee) i.e. Sh. Ashok Kumar Madan. Therefore, the cash receipt amounting to Rs. 1,00,00,000/- is undisclosed income of the assessee. S No Information code Issue description Amount (Rs.) 1. 2015-16 TDS Statement-Salary to employees (section 192) 5,84,959/- 2. 2015-16 TDS Statement-Purchase of Equity share Recognised stock exchange. 10,93,270/- 3. 2015-16 TDS Statement-Sale of Equity share Recognised stock exchange 3,50,849/- 4. 2015-16 TDS Statement-sales consideration on sale of immovable pr....
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....f the AO having, in his possession, an email of the buyer i.e., Mohd Athar Anjum, does not find mention in the notice issued under Section 148A(b) of the Act. 14.1 As is evident from paragraph 2.2 of the order passed under Section 148A(d) of the Act, which has been extracted hereinabove, the AO has not mentioned the date of the email. 14.2 As indicated hereinabove, the AO had noted in paragraph 2.2 of the order passed under Section 148A(d) of the Act that the email is indicative of the fact that the petitioner has received "at least" Rs. 1 crore. 15. We are unable to appreciate what has been noted in paragraph 2.2 concerning the amount said to have been received by the petitioner. The email would have either indicated an amount or ....