2023 (6) TMI 1503

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....1, 946 of 2012, 737 of 2012 - -<br>Income Tax<br>K.R. Shriram And Firdosh. P. Pooniwalla, JJ. Mr. P. J. Pardiwalla, Senior Advocate a/w Mr. Nitesh Joshi, Mr. Atul K Jasani, Mr. Ashok Boghani & Co. for Petitioner in WP/745/2009 and for Respondent No.&nbsp;1 in WP/2849/2008. Mr. Siddharth Chandrashekhar for Petitioner in WP/1326/2013, Mr. Subit Kumar for Petitioner in WP/2434/2011 and WP/2433/....

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....x Act 1961. This petition came to be admitted on 17th March 2009. 2 In view of this petition being filed by the Revenue, assessee, namely Marico Ltd, filed writ petition no.745 of 209 on 13th April 2009 for a writ of certiorari calling for records of petitioner's case with the Revenue and after examining legality and validity thereof, quash and set aside the authorisation dated 20th October 201....

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.... or any authority or ITAT. 4 Mr. Pardiwalla, relying upon the Judgment of the Apex Court in Principal Director of Income-tax (Investigation) Vs. Laljibhai Kanjibhai Mandalia [(2022) 140 taxmann.com 282 (SC)] submitted that it is open to court to examine the question whether "reasons to believe" have any rational connection or a relevant bearing to the formation of the belief and that such reaso....