2024 (11) TMI 1443

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....N For the Petitioner : Mr.S.Sathiyanarayanan For the Respondent : Mr.S.Rajasekar Standing Counsel ORDER In this Writ Petition, the petitioner has challenged the impugned notice dated 30.03.2021 issued under Section 148 of the Income Tax Act, 1961 for the assessment year 2014-15. Pursuant to the above notice, the assessment that was earlier completed on 29.01.2018 under Section 143(3) r....

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....deduction claim under section 35D being 1/5 th share issue expenses of Rs.37,60,13,629/- and for general corporate purpose and issue expenses Rs.160,84,09,967/- were all subject matter of scrutiny before the assessment order dated 29.01.2018 was passed. 4. Specifically, a reference was made to the response of the petitioner dated 22.06.2016 in response to notice issued under 143(2) of the Incom....

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....pleted on 29.01.2018. 6. He further placed reliance of the judgement of the Hon'ble Supreme Court in Calcutta Discount Co.Ltd Vs. Income-tax officer reported in 1961 41 ITR 191 SC and also placed reliance on the judgement of this Court in The Principal Commissioner of Income Tax Vs M/s. Mansi Finance (Chennai) Ltd in Tax Case Appeal No.71 of 2021. 7. That apart, the learned counsel for t....

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....der disposing of objection on 24.01.2022, the respondent has merely brought out the point that, as stated in the reasons recorded and also detailed discussion in the said order is apparent that the AO has necessary information in his possession that assessee company had abandoned projects in respect of which it has claimed depreciation at a rate higher than what it was entitled to which it has cla....