Dhunna Investment P Ltd. v. Income Tax Officer Ward 7(1) Delhi & Ors.
Case brief
What is this about?
faceless assessment; Section 144B procedural; jurisdictional Assessing Officer concurrent jurisdiction; Section 148 notice validity; Section 151 approval by Joint Commissioner post 01.04.2021 invalid; TOLA Section 3 exclusion 20.03.2020-30.06.2021; Rajeev Bansal; Ashish Agarwal; Hexaware Technologies doubted; search reassessment Section 153A/153C versus 147/148; DIN Circular 19/2019 left open (Brandix SLP); meaning of 'information' left open (W.P.(C) 1023/2024); Talati Gujarat followed in tune; batch disposal with directions to AOs; W.P.(C) 3908/2023 & Connected Matters.
What did the court decide?
Batch of writ petitions disposed of with directions to the concerned Assessing Officers to evaluate each Section 148 notice in light of T.K.S. Builders, Abhinav Jindal and Naveen Kumar Gupta and to determine surviving limitation per Rajeev Bansal and Ram Balram, by passing reasoned and speaking orders; interim orders to continue meanwhile; liberty to the writ petitioners to file written submissions within three weeks and to assail any adverse orders; challenge in W.P.(C) 6849/2023 on limitation held to fail.