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2021 Supreme(Mad) 898

S.M.SUBRAMANIAM
S. Ganesan – Appellant
Versus
Assistant Commissioner of Income Tax, Chennai – Respondent


Advocates:
Advocate Appeared:
For the Petitioner:R. Sivaraman, Advocate.
For the Respondent: A.P. Srinivas, Senior Standing counsel.

JUDGMENT :

(Prayer: Writ Petition filed under Article 226 of the Constitution of India, to issue a Writ of Certiorari, quash the impugned notice issued u/s.148 of the Act in Pan No.AAZPG3716G/ACIT/NCC-15/A.Y.2010-11 dated 31.3.2017 and consequentially quash the proceedings in Pan : AAZPG3716G/Reply to objections/NCC 15(1)/2017-18 dated 22.12.2017 as illegal and without jurisdiction.)

1. The Notice issued under Section 148 of the Income Tax Act, 1961 in proceedings dated 31.03.2017 and the reply to the objections given by the respondents for re-opening of assessment in the case of the petitioner in proceedings dated 22.12.2017 for the Assessment Year 2010-11 are under challenge in the present writ petition.

2. The petitioner was engaged in the business of investment advice to the clients in Mutual Funds, post office saving scheme, insurance companies and other deposits. He was assessed to tax under PAN No.AAZPG3716G on the file of the respondent. For the Assessment Year 2010-11, the petitioner had filed return of income on 30.07.2010, declaring a total income of Rs.4,46,870/-. The return was processed under Section 143(1) on 08.04.2011. Subsequently, the assessment was taken up for scr

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