ORDER

% 22.05.2024 CM APPL. 31192/2024 (Ex.) Allowed, subject to all just exceptions.

The application stands disposed of.

W.P.(C) 7489/2024 and CM APPL. 31191/2024 (Stay)

1. We take note of the challenge which stands raised in the instant writ petition and to the reassessment action which has been initiated.

As would be evident from a reading of the impugned notice issued under Section 148A(b), the respondents had essentially taken notice of certain transactions which were reflected in the GST returns. On the basis thereof, they formed the opinion that total transactions amounting to INR 26,22,79,508/- had escaped assessment.

2. Although the petitioner had, while responding to an earlier notice under Section 133(6) of the Income Tax Act, 1961 [‘Act’]

provided all details, it additionally filed a detailed reply upon receipt of the aforenoted communication.

3. Principally and for the purposes of examining the challenge at this stage, we take note of the following stand which was taken by the petitioner:-

“2.Your goodself rightfully shared the summary of GST returns filed by Agoda Singapore during the period AY 2020-21. However, the said compliance bas been undertaken owing t