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DELHI HIGH COURT
MANMOHAN, NAVIN CHAWLA
Alpha Corp Development Private Limited – Appellant
Versus
Assistant Commisisoner of Income Tax – Respondent


Table of Content
1. (Para 1 , 2 , 3 , 4 , 7 , 8 , 9 , 10)

JUDGMENT

Manmohan, J. (Oral)--Present writ petition has been filed challenging the demand notices dated 22nd November, 2021 and 06th December, 2021.

2. Learned Counsel for the Petitioner states that the Respondents have threatened to initiate recovery proceedings against the Petitioner if the alleged outstanding demand of Rs. 1,02,12,560/-is not paid within seven working days.

3. Learned Counsel for the Petitioner states that in the computation sheet supplied with the assessment order, there are various errors apparent on the face of the record. He states that the Petitioner's income under the head "Income from Business and Profession" was taken to be Rs.19,43,61,300/-, whereas in the ITR the amount was Rs.14,91,74,703/-, which created a differential income of Rs.4,51,86,597/-. He points out that the TDS credit had been taken to be only Rs.56,29,668/-, even when in the ITR it was disclosed as Rs.56,69,044/-, thus creating a differential amount of Rs.39,376/-.

4. Learned Counsel for the Petitioner states that though the rectification application was filed by the petitioner on 27th April, 2021 and the statutory period as

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