2023 (1) TMI 1549

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....or the Petitioner : Mr Robin Ratnakar David, Mr Dhiraj Philip & Mr Samuel David, Advocates. For the Respondent : Mr Sunil Agarwal, Sr. Standing Counsel, on behalf of Mr Kunal Sharma, Sr. Standing Counsel. RAJIV SHAKDHER, J (ORAL): W.P.(C) 937/2023 & CM APPL. 3664/2023 [Application filed on behalf of the petitioner seeking interim relief] 1. Issue notice. 1.1 Mr Sunil Agarwal, learne....

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....l from multiple foreign entities in tranches. It is alleged that payments have been received from "tax haven countries like Dubai, Mauritius, Greece and Cayman Islands". 5. A perusal of the impugned order shows that the input based on which reassessment proceedings have been triggered, is the Tax Evasion Petition (TEP). 6. A perusal of the record also shows that the petitioner/assessee had f....

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....t material supporting the allegations leveled against the petitioner. 8. We may also note that both vis-a-vis the preceding AY i.e., AY 2016- 17, as well as the AY in issue i.e., AY 2017-18, assessment orders under Section 143(3) were passed. 9. Given the aforesaid position, we are of the view that the AO would have to carry out a de novo exercise. 9.1 It is ordered accordingly. 10. Th....