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2022 (9) TMI 1110 - DELHI HIGH COURTReopening of assessment u/s 147 - petitioner states that notice issued u/s 148A(d) rejecting the contentions of the Petitioner on the ground that the Petitioner had not submitted any supporting evidence to show that the alleged information was incorrect and therefore the transaction undertaken by the Petitioner remained unexplained - HELD THAT:- It is not understood by this Court as to how the petitioner can prove the negative - It is pertinent to mention that no instance of any transaction between the petitioner and Mr.Naresh Manakchand Jain has been placed on record by the AO. Issue notice. Mr.Abhishek Maratha, learned counsel for the respondent-revenue accepts notice. He prays for and is permitted to obtain instructions within two weeks. List on 6th September, 2022.
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