Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2023 (3) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (3) TMI 524 - HC - Income TaxReopening of assessment u/s 147 - Period of limitation to issue notice issued u/s 148A(b) - power to extend the time period under the first proviso to section 149(1) - frequent high value transactions through transfer and through RTGS in the account - information has been flagged on the insight portal as uploaded by the Directorate of Income Tax (Systems) after risk profiling based on enquiry reports and finding of Directorate of Income Tax (Investigation) and Directorate of Investigation & Criminal Investigation - respondent authorities has forcefully argued before this Court that the case is covered under the Explanation in Section 149 where the asset also includes the deposits in the bank account, moreover, it is not an exhaustive definition but, by all means an inclusive definition - HELD THAT:- Having heard both the sides and having also considered the material on the record, the aspect that needs to be considered by this Court is as to whether any interim relief at this stage is necessary, since the re-assessment for the AY 2015-16, 2016- 17 and 2017-18 continue, pursuant to the notice issued under Section 148 of the Act in post Union of India versus Ashish Aggarwal [2022 (5) TMI 240 - SUPREME COURT] At this stage, learned advocate, Mr.Hardik Vora seeks permission to withdraw these petitions - Permission, as prayed for withdrawal, is granted keeping all contentions open for the petitioners.
|