TMI Blog2021 (12) TMI 1139X X X X Extracts X X X X X X X X Extracts X X X X ..... 3(3) of the Act. In the reasons recorded indicate the grounds on which re-assessment is sought to be initiated. Paragraph 3.1 starts with the words, During the year, in the submissions furnished by the assessee, it is found that the assessee company had shown 7 outlets but the company showed sales only from 2 outlets, i.e., one at Bandra and other at Colaba, debited expenses on account of 7 ou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated:- 14-12-2021 - K. R. SHRIRAM AND AMIT B. BORKAR, JJ . Mr. Rohan Deshpande a/w Ms. Rucha Vaidya i/b Farzeen Khambatta for Petitioner. Mr. Sham V. Walve a/w Mr. Pritish Chatterjee for Respondents Revenue. ORDER P. C. :- 1. Petitioner is impugning a notice dated 30/03/2019 issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the Act ) fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Mr. Deshpande submitted that if one considers the reasons provided, there is nothing to even indicate any material fact has been not disclosed. 4. No reply has been filed though time was granted on 25/11/2019 and further time was granted on 30/01/2020. Mr. Walve submitted that there is no change of opinion and the reasons indicate that there has been non-disclosure of material facts. Mr. Walve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ll the 7 outlets when sales was shown only from 2 outlets. Paragraph 3.1 ends with the words, . therefore, the said expenditure cannot be allowable as business expenditure during the relevant AY 20120-13 being expenditure not related to the period under consideration . This is certainly change of opinion. 6. Paragraph 3.2 also relates to payment of rent for 5 outlets and repairs and renovat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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