DARSHAN JITENDRA JHAVERI Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) Since pleadings are completed, we decided to dispose this petition at the admission stage itself.

(2.) Petitioner is a non resident Indian since 2001 residing in Hong Kong. Petitioner has been conducting business through and in the name of various legal entities, of which petitioner was either the sole shareholder and/or one of the shareholders. These corporate entities were set up either in Hong Kong or in British Virgin Islands (BVI). It is stated in the petition that since 2013-2014 petitioner 's only source of income is out of investments in India and outside India. Petitioner has been filing income tax returns as NRI since 2001. According to petitioner, all assessments are completed including in respect of the returns filed for Assessment Year 2018-2019.

(3.) Petitioner received an intimation dated 20th June 2019 under Section 127 (1) of the Income Tax Act, 1961 (the Act) informing petitioner that a search and seizure action under Section 132 of the Act was conducted on 27th July 2017 in the case of Salagaocar Group of Companies by Pr. DIT (Inv.) Panji and these cases are proposed to be centralized with ACIT (Central) Circle, Goa. Paragraphs 1, 2 and 3 of the intimation dated 20th June 2019 read as under :