2025 (11) TMI 1009

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....ent. 2. The present writ petition is filed by the petitioner challenging the notices as well as order at Annexure-A to Annexure-C i.e. (i) the notice dated 10.03.2023 issued under Section 148A(b) of the Income Tax Act, 1961, (for short, "the Act") (ii) the order dated 10.04.2023 passed under Section 148A(d) of the Act, rejecting the petitioner's objections for initiation of reassessment proceedings for Assessment Year 2019-20, and (iii) the consequential notice dated 10.04.2023 issued under Section 148 of the Act. 3. The petitioner is a private limited company operating a division under the name "Green Channel Travel Services", which is an RBI-licensed Authorised Dealer Category-II engaged in foreign exchange activities governed under....

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....tural justice. It is further submitted that the petitioner repeatedly requested for the said report in its response, but the same was furnished for the first time only along with the affidavit-in-reply. It is submitted that only on this sole count, the writ petition may be allowed by setting aside the impugned show cause notices as well as the order dated 10.04.2023 under Section 148A(d) and further notice dated 10.04.2023 issued under Section 148 of the Act. 7. Opposing the aforesaid submissions of the learned advocate Mr. Soparkar, learned Senior Standing Counsel Mr. Dev Patel has submitted that the petitioner was previously issued summons under Section 131(1A) calling for all the details for the financial years 2017-18 and 2018-19 and....