2025 (11) TMI 1957

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... For the Petitioner Through: Ms. Divyanshi Singh and Mr. Dhruv Dev Gupta, Advs. For the Respondent Through: Mr. Siddhartha Sinha, SSC and Mr. Nring Chamwibo Zeliang, Adv. ORDER 1. The matter is taken up today as the date fixed, i.e. 25.11.2025 was declared a holiday pursuant to Notification No. 35/G-4/Genl-I/DHC dated 24.11.2025, issued by this Court. 2. This petition has been filed....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... ITA, 1961, of ITA, 1961 by Respondent No. 1 initiating reassessment proceedings for AY 2020-21, without authority and jurisdiction, in violation of provisions of the Income Tax Act, 1961 and that of principles of natural justice and in violation of Article 14, 19(1)(g), 265 and 300A of the Constitution of India;" 3. In substance, the challenge is to a notice dated 21.03.2024 issued under Secti....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....petitioner/assessee and in that sense it is unable to reconcile the figure of Rs. 3,16,00,000/- from their books of accounts. In any case, an order under Section 148A(d) of the Act was passed by the respondents on 12.04.2024 followed by a notice under Section 148 of the Act. 6. Pursuant thereto, the notice dated 21.07.2025, was issued under Section 142(1) of the Act by the Assessing Officer see....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e hand the petitioner had filed a brief reply seeking further time to file a reply but on the other, has alleged that in the absence of any information furnished by the AO in respect of the 126 entities, they are unable to file a detailed reply to the same. 8. According to him, in the given facts, when the petitioner is evading to give a proper reply and also till date has not furnished informa....