NIRMALJIT KAUR
MARUDHAR HOTELS PRIVATE LIMITED – Appellant
Versus
ASSISTANT COMMISSIONER OF INCOME – Respondent
Nirmaljit Kaur, J.
All the above mentioned writ petitions shall stand decided by this common order as the issue involved is identical.
2. For convenience, the facts are being taken from S.B. Civil Writ Petition No. 5053/2013.
3. By way of present writ petition, the petitioner is seeking quashing of the Notice dated 28.03.2012 issued by the respondent No.1 under Section 148 of the Income Tax Act, 1961 and the proceedings pursuant thereto, including and particularly Order dated 28.03.2013 passed by the respondent No.1 under Section 147/143(3) of the Income Tax Act, 1961 reassessing the income of the petitioner.
4. While praying for setting aside the impugned notice, learned counsel for the petitioner contended that despite the original assessments having been made by the Assessing Authority under Section 143 (3) of the Income Tax Act, 1961 (for short “the Act of 1961” hereinafter) upon scrutiny of the record of the petitioner assessee, the Assessing Authority has reopened the assessments under Sections 147/148 of the Act of 1961 for the Assessment Years 2005-06, 2006-07 and 2007-08, mainly on two reasons, viz, firstly that the interest/deduction claimed under Section
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