2025 (4) TMI 1302

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... -<br>Income Tax<br>M. S. SONAK & JITENDRA JAIN, JJ. For the Petitioner: Mr. Rohan Deshpande i/b. Ms. Alisha Pinto, Advocates,. For the Respondents: Mr. Akhileshwar Sharma a/w. Ms. Shraddha Worlikar, Advocates,. ORAL JUDGMENT (PER : JITENDRA JAIN, J.) 1. Heard learned Counsel for the parties. 2. Rule. Rule is made returnable forthwith. By consent, the Petition is taken up for final heari....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... and truly all material facts necessary for the assessment. 7. On a perusal of the reasons recorded which are reproduced above, there is no allegation of any failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. Even on a perusal of the reasons recorded, the said pre-condition cannot be discerned with even in the absence of such allegatio....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ia) is concerned, a query was raised by the Respondents in the course of the assessment proceedings vide notice dated 18.07.2016 and same was replied by the assessee vide letter dated 09.11.2016, wherein all the details with respect to the TDS were furnished. The details are also filed along with this Petition from page 125 to 135. Therefore, on both these grounds i. e. deduction under Section 80P....