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2023 Supreme(Del) 1943

RAJIV SHAKDHER, TARA VITASTA GANJU
Delhi Sports And Entertainment Private Limited – Appellant
Versus
Deputy Commissioner of Income Tax Circle 7 1 – Respondent


Advocates appeared:
Mr Robin Ratnakar David, Mr Dhiraj Philip & Mr Samuel David, Advocates, for the Petitioner.
Mr Sunil Agarwal, Senior Standing Counsel, on behalf of Mr Kunal Sharma, Senior Standing Counsel, for the Respondent.

JUDGMENT

[Physical Hearing/Hybrid Hearing (as per request)]

Rajiv Shakdher, J. (Oral):

W.P.(C) 937/2023 & CM APPL. 3664/2023 [Application filed on behalf of the petitioner seeking interim relief]

1. Issue notice.

1.1. Mr Sunil Agarwal, learned senior standing counsel, accepts notice for Mr Kunal Sharma, on behalf of respondent/revenue.

2. In view of the directions that we propose to pass, Mr Agarwal says that, at this stage, counter-affidavit is not required to be filed. Therefore, the writ petition is taken up for hearing and final disposal, at this stage itself.

3. This writ petition is directed against the order dated 30.07.2022 passed under Section 148A(d) of the Income Tax Act, 1961 [in short, 'the Act'] and the consequent notice of even date, 30.07.2022, issued under Section 148 of the Act.

3.1. The impugned order and the notice concern Assessment Year (AY) 2017-18.

4. The principal allegation leveled against the petitioner/assessee is that it has received money by way of investment in share capital from multiple foreign entities in tranches. It is alleged that payments have been received from "tax haven countries like Dubai, Mauritius, Greece and Cayman Islands".

5. A per

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