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2021 (5) TMI 121

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..... Section 153C of the Income Tax Act would show that there is no escapement of the income, even according to the respondent. Counter affidavit itself, it has been fairly conceded in paragraph 20 that there is no change in the demand amount and that the overall demand raised in respect of the assessee and that no further additional demand has been raised by the impugned order. If there is no escap .....

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..... . The petitioner filed its e-return of income on 28.09.2013, admitting an income of ₹ 66,77,810/-.The return of income was selected for scrutiny. The assessment order under Section 143(3) of the Income Tax Act, 1961 was passed on 28.03.2016 and the following additional determination of income was made:- Total income returned ₹ 66,77,810 .....

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..... was a sale transaction between the two parties. Based on the same, after issuing notice under Section 153C, the impugned order dated 30.12.2016 came to be passed. Questioning the same, the present Writ Petition has been filed. 4.The respondent filed a detailed counter affidavit. The learned Standing Counsel appearing for the respondent took me through the contents set out therein. The responden .....

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..... Demand Payable ₹ 2,01,42,550 6.As rightly pointed out by the learned counsel for the petitioner, a bare comparison of the Assessment order passed under Section 143(3) of the Income Act and the impugned order passed under Section 153C of the Income Tax Act would show that there is no escapement of the income, even according to the respondent. In fact, the .....

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