2025 (3) TMI 1013

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... S. Padvekar with Mr. Tanzil Padvekar and Ms. Tejal P. Kharkar, Advocates. For the Respondent-Revenue: Ms. Samiksha Kunani, Advocate. PC (PER M. S. SONAK, J.):- 1. Heard learned counsel for the parties. 2. This petition relates to the assessment year 2017-18. 3. The Petitioner challenges a notice dated 30 March 2021 issued under Section 148 of the Income Tax Act, 1961 (the Act), see....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Section 142 (3) of the Act. He submitted that queries were raised, and such queries were duly answered. Upon consideration of the answers, the assessment was completed. He submitted that in such circumstances, there was no scope for reopening of the assessment. Mr. Padvekar furnishes a compilation of 10 decisions but stresses on Aroni Commercials Limited Vs. Deputy Commissioner of Income Tax 2(1) ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....g the correct date of appointment of Mr. Ajay Pratap Singh. He submits that Mr. Ajay Pratap Singh was in fact, appointed on 10th February 2016 and not on 10th February 2017. Similarly, regarding Mr. Rahul Mahajan, it is now claimed that the explanation earlier offered incorrectly mentioned him. 9. Thus, wherever inconvenient, the Petitioner is now coming up with some defence which is prima faci....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....xplanations regarding the cash deposits by Mr. Ajay Pratap Singh, Mr. Rahul Mahajan and Mr. Kumar Jayendra. Apart from the quality of the explanations, at least prima facie, they appear to be in a nature of after-thoughts. We are afraid that we cannot go into such factual aspects when deciding whether the jurisdictional parameters for re-opening the assessment were fulfilled. Based on the facts of....