LUPIN LIMITED vs DEPUTY COMMISSIONER OF INCOME TAX 3 (4) AND 2 ORS.

Judgment text excerpt

35-WP-1530-2022 (F).DOCX DARSHAN PRAKASH PATIL Darshan Digitally signed by DARSHAN PRAKASH IN THE HIGH COURT OF JUDICATURE AT BOMBAY PATIL Date: 2025.02.20 ORDINARY ORIGINAL CIVIL JURISDICTION 14:11:16 +0530 WRIT PETITION NO. 1530 OF 2022 Lupin Limited …Petitioner Versus Deputy Commissioner of Income Tax-3(4), Mumbai and Ors. …Respondents ______________________________________________________ Mr Jeet Kamdar, i/b Mr Atul K Jasani, for the Petitioner. Mr Suresh Kumar, for the Respondent. ______________________________________________________ CORAM: M.S. Sonak & Jitendra Jain, JJ. DATED: 18 February 2025 Oral Judgment (per M S Sonak, J.):- 1. Heard learned counsel for the parties. 2. Rule. The Rule is returnable at the request of and with the consent of learned counsel for the parties. 3. This Petition relates to the assessment year 2016-2017. 4. The Petitioner challenges the notice dated 31 March 2021 issued by the first Respondent under Section 148 of the Income Tax Act, 1961 (“IT Act”) seeking to reopen the assessment for A.Y. 2016-17 together with consequential notices and orders and order dated 30 November 2021 rejecting the Petitioner’s objections to the reopening of the assessment. 1 35-WP-1530-2022 (F).DOCX 5. The Petitioner filed its return of income on 26 November 2016, declaring a total income of Rs.26,36,01,64,390/-. The Petitioner’s case was selected for scrutiny, and various details were called for via notices dated 19 September 2017, 13 July 2018, 18 September 2018, 24 October 2018 and 03 December 2018. 6. In the notice dated 18 September 2018, the Petitioner was called upon to furnish information and explain the amounts considered disallowable and allowable in the computation of income. The Petitioner was also called upon to furnish information regarding ce