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TMI Blog2022 (3) TMI 1290X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax X X X X Extracts X X X X X X X X Extracts X X X X ..... n offered to tax by the assessee. It is further stated in the impugned order that the plea of the petitioners'-assessee is covered under Para 1(B)(iii)(c) of the CBDT instruction regarding selection of potential cases for issue of notice under Section 148 of the Act issued vide F. No. 225/40/2021/ITA-II dated 15th March, 2021. 4. Learned senior counsel for the Petitioners submits that the impugne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... imed exemption and therefore, the issue will have to be examined during the re-assessment proceedings. 7. In the present cases, the issue of dividend income as well as long term capital gain on the sale of shares requires a detailed consideration. 8. Further, in the present cases, Section 148 notices have been issued within four years from the end of the relevant Assessment Years. Also no scruti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se. However, the contentions and submissions raised by the petitioner are relevant and must be examined by the Assessing Officer while passing the reassessment order. It will also be open to the assessee to show in the re-assessment proceedings that the assumption of facts made in the notice is erroneous. 10. With the aforesaid direction, the present writ petitions along with pending applications ..... X X X X Extracts X X X X X X X X Extracts X X X X
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