TMI Blog2022 (8) TMI 250X X X X Extracts X X X X X X X X Extracts X X X X ..... Rakesh Gupta, Dr. Rakesh Kumar, Mr. Somil Agarwal and Mr. Anshul Mittal, Advocates. Respondents Through: Mr. Ruchir Bhatia, Sr. Standing Counsel for Revenue with Ms. Mansie Jain, Advocate. Mr. Rajnish Kumar Gaind, SPC for R-3/UOI. J U D G M E N T MANMOHAN, J (Oral): CM APPL. 33402/2022 Exemption allowed, subject to all just exceptions. Accordingly, present application stands disposed of. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the entities in whose scrips it traded. It was further alleged in the said notice that as the information regarding the scrips was not provided during the assessment of VFSPL, prima facie all the transactions belonged to the Petitioner. It was also stated that since no details regarding these transactions were found to be declared in the Petitioner's ITR, the above transactions prima facie had res ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed without making any addition and accepting the returned income of the VFSPL. 5. Learned counsel for the Petitioner states that the impugned order under Section 148A(d) of the Act has been passed by the authorities without considering the detailed reply of the Petitioner filed in response to the impugned show cause notice dated 22nd March, 2022. He states that through its reply to the show case ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of VFSPL was not brought to the notice of the Assessing Officer and the said fact throws an entirely different light on the proceedings. 8. Having heard the learned counsel for the parties, this Court finds that if the averments in the writ petition are true and correct, then the scrutiny assessment of VSFPL had concluded even prior to the issuance of the notice under Section 148A(d) of the Act ..... X X X X Extracts X X X X X X X X Extracts X X X X
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