2025 (1) TMI 817

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.... returnable forthwith. Learned Senior Standing Counsel Mr. Karan Sanghani waives service of notice of rule on behalf of the respondent-State. 3. Having regard to the controversy involved arising in this petition which is in very narrow compass, with the consent of the learned advocates for the respective parties, the matter is taken up for hearing. 4. By this petition under Article 226 of the Constitution of India, the petitioner has prayed for the following reliefs: "A. This Hon'ble Court be pleased to call for the records of the proceedings, look into them and be pleased to issue a writ of certiorari or any other appropriate writ, order or direction quashing the impugned order u/s. 148A (d) dated 22.07.2022 at Annexure L an....

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....assessing total income at Rs. 3,30,30,840/-. 5.4 Subsequently, the petitioner received a notice u/s. 148 dated 29.06.2021 stating that income has escaped assessment and further asked the petitioner to file return of income within a period of 30 days from the date of receipt of the said notice. 5.5 In response to the aforesaid notice, the petitioner filed preliminary objections vide letter dated 13.08.2021 with regard to jurisdiction of Assessing Officer to issue a notice u/s. 148 in the old regime of reassessment after enactment of the Finance Act,2021. As the notice is issued u/s. 148 as per the erstwhile provision of section 148 even after the substitution of reassessment provisions by Finance Act,2021, the petitioner filed writ pet....

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....advocate Mr. Manish Shah submitted that so far as the issue of alleged expenses of Rs. 4,32,00,000/- debited to P & L account is concerned, the said issue has been accepted by the respondent-Assessing Officer in the impugned order passed under section 148A (d) of the Act. 6.1 It was further submitted that so far as the issue of eligibility of the assessee for deduction of Rs. 4,34,11,046/- under section 80P (2) (d) of the Act is concerned, the amount earned by the petitioner from the tax deposit held in Cosmos Cooperative Bank Limited. It was submitted that the issue of deduction under section 80P (2) (d) of the Act by the Cooperative Society on the interest income earned on the fixed deposit kept with the Cooperative Bank is now no more....