CITIBANK N.A Vs. S.K. OJHA

JUDGEMENT

(1.) Rule came to be issued on 23/1/2008 on which date the interim protection granted on 6/11/2001 was continued pending the hearing and final disposal of the petition.

(2.) Petitioner is a body corporate incorporated in the United States of America and has been carrying on business in India through its branches. Petitioner has been an assessee under the Income Tax Act, 1961 [hereinafter referred to as "the Act"].

(3.) By this petition, petitioner is challenging the action of respondent no.1 seeking to reopen the completed assessment of petitioner for the Assessment Year 1992-1993. According to petitioner, despite repeated request to provide the reasons to believe, petitioner was not provided the same. The same, however, is annexed to the affidavit in reply filed by respondent no.1.