2026 (1) TMI 1129

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...., i/b Adv. Rashmi Vyas,. For the Respondents: Adv. Suresh Kumar. P. C. 1. Rule. Respondents waive service. With the consent of parties, Rule made returnable forthwith and heard finally. 2. The above Petition is filed to quash and set aside notice dated 31st March 2021 issued by the 1st Respondent under Section 148 of the Income Tax Act, 1961. Additionally, the order disposing of the ob....

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....d that the Assessing Officer has reason to believe that the income of Rs. 100 Crores has escaped Assessment for A.Y. 2017-2018, and the same is, therefore, required to reopen for scrutiny assessment. Apart from this bald statement, nothing else is stated in the reasons. 4. According to the Revenue, the reason given is that information is received by the Revenue by virtue of a Tax Evasion Petiti....

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.... Petition, the Assessing Officer could never have had reason to believe that income to the extent of Rs.100 Crores had escaped assessment for A.Y. 2017-2018. For the sake of convenience, we are reproducing the Tax Evasion Petition, and on which reliance has been placed by the Assessing Officer in his reasons:- "Dear Sir Subject Income Tax Evasion I refer the Income tax e....

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....sed Yarn and other items in cash. The other method is by giving salary in cash. The monthly cash salary amount is 5 Crores. The company is having a workforce of 2500 people in Daman. The turnover of all companies is Rs. 500 crores. Recently the company has purchased residential properties worth 75 Crores in Breach Candy Area. The cash paid is Rs. 40 Crores for this property. ....