TMI Blog2016 (4) TMI 639X X X X Extracts X X X X X X X X Extracts X X X X ..... laundering such money without attracting the provisions of the relevant statute is by parking the same in obscure companies with little business activities by investing in shares therein at a huge premium. It is such aspect of the matter which has, quite appropriately, attracted the attention of income tax authorities qua the petitioning assessee. It is most desirable that the exercise be completed by taking the matter to its logical conclusion. - WP 4216 (W) of 2016 - - - Dated:- 22-3-2016 - Sanjib Banerjee, J. For the Petitioner : Mr Rajarshi Bharadwaj Mr B. Sengupta For the Respondent : Mr Siddhartha Bhattacharya ORDER This is an attempt by an assessee to deny a re-assessment. The matter pertains to assessment yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... presentation was considered by the Deputy Commissioner of Income Tax and a reply forwarded by such officer to the petitioning assessee on February 10, 2016. The petitioners claim that the reasons recorded by the assessing officer are erroneous and do not form any ground for reassessment. The petitioners also complain that the deputy commissioner has sought to deal with the petitioners representation without the deputy commissioner applying his independent mind to the matter. As to the Deputy Commissioner of Income Tax, Circle 4 (II), Kolkata taking up the matter, it appears that the jurisdiction over the case has been vested in the concerned deputy commissioner pursuant to an order dated August 19, 2015 passed under Sections 120 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity to reassess or the like and the protest must necessarily relate to the perceived failure to comply with the statutory requirements for the assumption of jurisdiction to issue the relevant notice. Ordinarily, the merits of the reasons, particularly when it deals with the treatment of a particular amount or transaction, may not be gone into at this stage since that would be the exercise of the reassessment or the like and the assessee would have a scope for redressal upon an adverse order being passed. Once reasons are recorded under Section 148(2) of the said Act, these are the reasons, including the jurisdictional facts, on which a notice under Section 148(1) of the said Act pertaining to a matter covered under Section 147 thereof wo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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