TMI Blog2022 (6) TMI 31X X X X Extracts X X X X X X X X Extracts X X X X ..... scharacterization of income - HELD THAT:- Issue notice. Mr.Puneet Rai, learned standing counsel accepts notice on behalf of the respondents. He states that the petitioner knew the stand of the Respondents-Revenue as a draft assessment order u/s 144C of the Act has already been passed in petitioner s case for the Assessment year 2017-18 on 30.09.2021, in which similar allegations had been made by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fore the next date of hearing. List on 01st September, 2022. - W.P.(C) 7784/2022 - - - Dated:- 20-5-2022 - HON'BLE MR. JUSTICE MANMOHAN AND HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA Petitioner: Mr.Percy Pardiwala, Sr.Advocate with Mr.Sachit Jolly, Mr.Rohit Garg, Ms.Disha Jham, Ms.Mehak Sachdeva And Mr.Sonum Dua, Advocates. Respondents: Mr.Puneet Rai, senior standing coun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... L ] had not been appropriately offered to tax due to mischaracterization of income. He, however states that the order dated 29th March, 2022 issued under Section 148A(d) of the Act states that the interest income earned by the petitioner in pursuance to the NCDs floated by GIPL was fictitious in nature and was, in fact, in the nature of dividend payment by GIPL, which is subject to dividend distri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssment year 2017-18 on 30.09.2021, in which similar allegations had been made by the Revenue and the said income had been categorized as Income from Other Sources falling under Article 22 of the Double Taxation Avoidance Agreement between India and Luxembourg. In rejoinder, learned senior counsel for the petitioner states that in the impugned order issued under Section 148A(d) of the Act, the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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