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2023 (4) TMI 1118 - DELHI HIGH COURTValidity of reopening of assessment u/s 147 - Increase in share capital - As it is the petitioner’s case, that insofar as the allegation with regard to the increase in share capital was concerned, this aspect was scrutinized by the AO while passing the order u/s 143(3) of the Act. Also allegation made in the notice issued under Section 148A(b) of the Act, and the order passed u/s 148A(d) does not seem to have etched out clearly, as to what is the connection in increase in share capital, and the transaction that the petitioner allegedly has entered into with RCI. HELD THAT:- Since a show-cause notice has been issued, and the reply is stated to be on the record, the AO will take the same into account, before he proceeds further in the matter. As noticed above, further reply was filed. In case the said reply is not on the record, the AO will give leave to the petitioner to have the aforesaid reply placed on record. The AO will take the said reply into account as well. Since the period for completing the assessment, we are told, is coming to an end on 31.03.2023, eight weeks are granted to the AO, to take a decision in the matter, commencing from the date of receipt of the copy of the judgement. Petitioner unreservedly, says that objections with regard to limitation having been passed, will not be put against the respondents/revenue. Writ petition disposed of.
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