TaxTMI 
TaxTMI 
2026 (9) TMI 2050
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....oner: Dr. Dhruv Janssen-Sanghavi, a/w Mr. Anirudh Srinivasan, Mr. Ichchhit Goswami, Mr. Vishesh Malviya, Ms. Aanchal Maheshwari, Ms. Shaili Shah,. For the Respondent: Adv. Subir Kumar, a/w Adv. Ashita Aggarwal,. P. C. 1. Mentioned at 11:00 AM, and with the consent of parties, taken on the production board at 3.00 PM. 2. The above Writ Petition is filed seeking to challenge the Show Cau....
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....ner. The Petitioner gave a detailed reply to the aforesaid SCN by its letter dated 22nd April 2026. 4. In response to the said letter of the Petitioner, the Revenue issued a letter dated 25th June 2026 now calling upon the Petitioner to disclose the source of funds for acquiring shares of the Mauritian entity. This issue was never raised in the SCN dated 31st March 2026. Be that as it may, this....
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....une 2026. This is apart from the fact that it is the case of the Petitioner that the Income Tax Department had no business to ask for the source of the funds of the Petitioner, who is a non-resident of this country. 6. Be that as it may, we are of the view that principles of natural justice have been violated since no adequate opportunity was given to the Petitioner to respond to the letter dat....
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....ly thereafter the Assessing Officer shall proceed to pass any order, if required, under Section 148A(3) and consequently issue notice under Section 148 of the Act. 9. It is needless to clarify that this exercise is being undertaken without prejudice to the rights and contentions of the Petitioner that they are not, in law, required to furnish the information sought for by the Income Tax Departm....