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2023 (10) TMI 1063

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..... ent under Section 148 of the Income Tax Act, 1961 for AY 2017-18 for PAN:AAAFN4271G. 2. Relevant portion of the impugned order reads as under:- 2. The assessee failed to file I.T Return for the AY 2017-18. In this case, the information available in ITBA database(NMS) assessee has made investment by purchase of time deposit to the tune of Rs. 14,00,000/- cash deposits of Rs. 1,63,91,100/- and interest income of Rs. 1,65,057/- in F.Y.2-2016-17 but failed to file the return of income declaring the above transaction for the AY 2017-18. The quantum of Rs. 1,79,56,157/- is escaped assessment for the A.Y 2017-18. Subsequently, the case was reopened u/s. 147 of the Income Tax Act and notice u/s 148 dated 19.03.2021 was issued and served. But the .....

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..... l part of this order. Copy of order, demand notice and notice u/s. 272A(1)(d)and 271AAC of the I.T.Act, 1961 are issued to the assessee. 3. The petitioner claims to be a partner of Nirmala Manure Stores which was engaged in the business of dealing with fertilizers. According to the petitioner, the said partnership firm was constituted in the year 1972 with two partners namely, petitioner and petitioner's father. The petitioner's father died on 18.01.2012 and thus the partnership stood dissolved on the same day by operation of law. 4. It is the specific case of the petitioner that the petitioner had intimated about the death of the petitioner's father, in his response dated 22.03.2022 to show cause notice dated 19.03.2022 issued un .....

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..... -, had made cash deposits of Rs. 1,63,91,100/- and had earned interest income of Rs. 1,65,057/- during the Financial year 2016-17 and thus a clear was case made out that income had escaped assessment for a sum of Rs. 1,79,56,157/-during Assessment Year 2017-18. 9. That apart, it is submitted no returns of income was also filed under Section 139 of the Income Tax Act and therefore the impugned order was passed. It is therefore submitted that the impugned order does not call for any interference. 10. I have considered the arguments advanced by the learned counsel for the petitioner and the learned Senor Standing Counsel for the respondents. 11. No doubt there is a failure on the part of the petitioner to have complied with the requirements .....

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