TMI Blog2023 (6) TMI 1343X X X X Extracts X X X X X X X X Extracts X X X X ..... ed the interim order as prayed for by the petitioner on the ground that the limitation is not applicable in the case of the petitioner and the assessment of tax is the fraudulent reversal of the Stock Exchange - HELD THAT:- Considered the rival submissions of the respective parties, this Court finds that the matter is required to be heard on merit only after exchange of affidavits and, as such, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iled by the petitioner be kept with the record. 2. Counsel for the respective parties are present. The petitioner has challenged the notice dated 28th July, 2022 issued under Section 148 of the Income Tax Act, 1961 relating to the assessment year 2015-16, and all subsequent proceedings based on the impugned notice dated 28th July, 2022 under Section 148 of the Income Tax Act, 1961, mainly on th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is not applicable in the case of the petitioner and the assessment of tax is the fraudulent reversal of the Stock Exchange. 4. Considered the rival submissions of the respective parties, this Court finds that the matter is required to be heard on merit only after exchange of affidavits and, as such, this Court, prima facie, is of the view that if, at this stage, no stay is granted, the petition ..... X X X X Extracts X X X X X X X X Extracts X X X X
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