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Notice U/s. 148 is invalid In absence of any live link with the reasons recorded and the belief formed
Case Law Details
- Case Name
- Prasad Koch Technik Tech Pvt. Ltd. Vs Assistant Commissioner of Income Tax (OSD)- Tax (Gujarat High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Gujarat High Court
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Prasad Koch Technik Tech Pvt Ltd Vs. Versus ACIT (Ahmedabad High Court)-
The Assessing Officer supplied reasons he had recorded for reopening the assessment, which read as under:- “The assessee company filed its return of income on 22.12.2006, declaring total income of Rs. 1,00,86,370/-. The assessment u/s. 143(3) was finalised on 18.06.2008 determining the taxable income of Rs. 1,00,86,370/-. It is seen that the assessee company had made payment of Rs. 21,60,399/- in Foreign Company for purchase of raw materials. However, neither did the company deduct TDS on this amount nor any certificat...
