Case Law Details
Vodafone Luxembourg 5 S A R L Vs Income Tax Department (Delhi High Court)
Learned counsel for Revenue emphasises that the petitioner’s case has been selected for reassessment only on the ground that the respondents has doubted as to whether interest was received by the petitioner-assessee on rupee denominated bonds issued by an Indian company or a dollar denominated bonds issued by an Indian company.
However, a perusal of the paper book reveals that petitioner’s case was selected for re-assessment on the ground that petitioner’s case was flagged in the Non-filers Monitoring System (NMS). Consequently, there is a contradiction between the reason given by the respondent in the reassessment notice and the defence taken by the respondent in the present proceeding.
Keeping in view the aforesaid, this Court quashes the impugned order and notices mentioned hereinabove and permits the respondent-revenue to issue a fresh re-assessment notice in accordance with law.
FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT
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