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The HC dismissed the petitioner's challenge to a reopening notice under section 148 of the Income Tax Act. The petitioner sold immovable property for Rs. 40 lakh to a third party through consent terms with a lender to satisfy debt, but failed to file any return of income disclosing this transaction. The petitioner argued denial of hearing opportunity under section 144B(6)(vii), violating natural justice principles. The HC held that since no return was filed, no hearing opportunity was required. The court found clear income escapement causing revenue loss and directed compliance with the impugned notice, rejecting the petition entirely.