SITARA DIAMOND PVT. LTD Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) This petition under Article 226 of the Constitution of India, challenges the notice dated 3 May 2012 issued for reassessment under Section 148 of the Income Tax Act, 1961 (in short "the Act") and the order dated 25 July 2012 dismissing the petitioner's objections while seeking to reassess the petitioner for the Assessment Year 200607.

(2.) At the very outset, it is made clear that though the petition as filed challenges the approval/sanction of the Commissioner of Income Tax (Respondent No.3) under Section 151 of the Act for issue of notice under Section 148 of the Act, no submission in respect of the same was advanced during the hearing before us. Therefore, as the challenge to Section 151 of the Act is not pressed before us, we are not dealing with the same.

(3.) Briefly the facts leading to the present petition are as under: