TMI Blog2023 (1) TMI 1126X X X X Extracts X X X X X X X X Extracts X X X X ..... lable to us, has been going on since 27.02.2019, when summons under Section 131(1A) of the Income Tax Act, 1961 [in short, 1961 Act ] were issued. Petitioner claims that he has filed not one, but three responses, setting out the details sought by the respondent/revenue. In this regard, reference is made to the replies dated 06.03.2019, 12.03.2019 and 05.04.2019, appended on pages 69, 77 and 79 of the case file. The record also shows that a summon was issued, once again, to the petitioner after nearly three years on 31.01.2022, under Section 131(A) of the 1961 Act; which was also replied to by the petitioner on 11.02.2022. Insofar as the 2015 Act is concerned, notice, in the first instance, under Section 8 of 2015 Act was issued on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect to just exceptions. W.P.(C) 17524/2022 CM Appl.55909/2022[Application filed on behalf of petitioner seeking interim relief] 2. Issue notice. 2.1 Mr Sanjay Kumar accepts notice on behalf of the respondent/revenue. 3. In view of the directions that we intend to pass, Mr Kumar says that a counter-affidavit is not required to be filed. Therefore, with the consent of the parties, writ petition is taken up for hearing and final disposal, at this stage itself. 4. Challenge is laid in this writ petition to the show cause notice dated 12.09.2022, whereby proceedings under Section 43 of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 [in short, 2015 Act ] were sought to be initiated. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,67,352/-, 9. Thus in sum, it is contended by Mr Kapoor on behalf of the petitioner, that there was no undisclosed foreign income or assets and therefore, the provisions of the 2015 Act have been wrongly triggered. 10. We may also note that this inquiry vis- -vis the petitioner, as per the record which is made available to us, has been going on since 27.02.2019, when summons under Section 131(1A) of the Income Tax Act, 1961 [in short, 1961 Act ] were issued. 11. The petitioner claims that he has filed not one, but three responses, setting out the details sought by the respondent/revenue. In this regard, reference is made to the replies dated 06.03.2019, 12.03.2019 and 05.04.2019, appended on pages 69, 77 and 79 of the case file. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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