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2023 Supreme(Bom) 194

DHIRAJ SINGH THAKUR, KAMAL KHATA
Devkant Synthetics India Pvt. Ltd – Appellant
Versus
Additional/Joint/Deputy/Assistant Commissioner Of Income Tax Offcer – Respondent


Advocates:
Counsel for Appearing Parties
Nishant Thakkar, Advocate, Jasmin Amalsadvala, Advocate, Akhileshwar Sharma, Advocate, Shilpa Goel, Advocate

JUDGMENT

Dhiraj Singh Thakur, J. - The petitioner in the present petition challenges the reassessment proceedings initiated pursuant to a notice, dated 31st March 2022 issued under section 148 of the Income Tax Act, 1961 ('the Act') leading to the fnal order of reassessment, dated 26th March 2022 relevant to the assessment year 2013-14. Demand notices as also the penalty notice, both dated 26th March 2022, pursuant to the passing of the order of reassessment are also challenged in the present petition.

2. Briefy stated the material facts are as under :

2.1 The petitioner is a company engaged in the business, inter-alia, of trading in shares and securities. It is stated that during the previous year relevant to the assessment year 2013-14, shares and securities amounting to Rs.36,04,65,386/- were traded. It is stated that after considering the purchase costs and other business expenditures, the petitioner reported a proft before tax of Rs.63,68,739/- in its Proft and Loss account for the year ending 31st March 2013.

2.2 A return of income for the assessment year 2013-14 was fled dec

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