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2021 Supreme(Del) 93

RAJIV SHAKDHER, TALWANT SINGH
Synfonia Tradelinks Pvt. Ltd. – Appellant
Versus
Income Tax Officer – Respondent


Advocates:
Advocate Appeared:
For the Petitioners: Mr. Udaibir Singh Kochar, Ms. Kunjala Bhardwaj.
For the Respondents: Ms. Vibhooti Malhotra, Mr. Shailendra Singh.

JUDGMENT :

RAJIV SHAKDHER, J.

Preface:

1. This writ petition is directed against notice dated 31.03.2018, issued under Section 148 of the Income Tax Act, 1961 [hereafter referred to as ‘the Act’] and the sanction accorded by respondent no. 2 i.e. the Principal Commissioner of Income Tax, Delhi-VIII on 29.03.2018 for issuance of notice under Section 148 of the Act. The assessee, being aggrieved, has moved this court via the instant writ petition.

Background facts:

2. To adjudicate upon the writ petition, the following broad facts are required to be noticed:

    2.1. The assessee before us is a private limited company going by the name Synfonia Tradelinks Pvt. Ltd. The assessee was incorporated on 28.05.1993 under the Companies Act, 1956 albeit under the name Synfonia Pharmaceuticals Pvt. Ltd. On 31.03.2015, the assessee changed its name to Synfonia Tradelinks Pvt. Ltd.

2.2. The income tax return for the assessment year [in short ‘AY’] 2010-2011 along with the balance sheet as on 31.03.2010 was filed by the assessee, on 23.09.2010.

2.3. Insofar as the succeeding year was concerned, which is

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