2025 (7) TMI 897

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..... Y. V. Raviraj, Advocate). ORAL ORDER 1. The petitioner has impugned the notices issued under Section 148 of the Income Tax Act, 1961 [for short, 'the IT Act'], the orders disposing of the petitioner's objections for reassessment, the reassessment orders and the demand notices. These impugned notices and orders [Annexures - A1, A2, A3, B1, B2, B3, C1, C2, C3, D1, D2 and D3] are fo....

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....hat income has escaped tax, and the petitioner is served with an extract of the reasons but not the reasons as recorded in the Assessment Orders. The petitioner has filed objections, and the petitioner inter alia has contended that it has not been shown a copy of the prior approval that has to be taken and that even if the interest received from the Holding Company is treated as Income from Other ....

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....owever, what remain as uncontroverted are that the petitioner has not been shown prior approval [admittedly, a must for commencement of reassessment proceedings] and that the Assessing Officer has not considered whether even if the interest received from the petitioner's Holding Company is declared as Income from Other Sources, the petitioner would be entitled for allowance as an Expenditure o....