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2023 (2) TMI 1275 - DELHI HIGH COURTReopening of assessment - foreign outward remittance is income chargeable to tax on the ground it has allegedly escaped assessment - principal allegation leveled against the petitioner is that it has failed to collect withholding tax in respect of remittances made to an Associated Enterprise(USA) - as petitioner sought 10 days’ time to furnish a response to the notice issued u/s 148A(b) but AO seems to have not addressed his mind to the request for accommodation made by the petitioner, and proceeded to pass, as indicated above, an order u/s 148A(d) of the Act, on the very next day, i.e., 05.04.2022. HELD THAT:- As to whether this resulted in a breach of principles of natural justice will also be examined on the next date of hearing. The matter requires further examination. Issue notice. Respondent accepts notice on behalf of the respondents/revenue.Counter-affidavit will be filed within the next four weeks. Rejoinder thereto, if any, will be filed at least five days before the next date of hearing. List the matter on 25.09.2023.
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