TATA COMMUNICATIONS LIMITED vs DEPUTY COMMISSIONER OF INCOME TAX-1(3) (1) AND 3 ORS

Judgment text excerpt

Digitally signed PRACHI by PRACHI PRANESH 1 1.WP.2486.22(J).docx PRANESH NANDIWADEKAR NANDIWADEKAR Date: 2025.03.07 15:27:41 +0530 Revati IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION WRIT PETITION NO.2486 OF 2022 Tata Communications Limited ) having its address Videsh Sanchar Bhavan, ) M.G. Road, Fort, ) Mumbai – 400 001. ) .. Petitioner Versus 1. Deputy Commissioner of Income Tax-1(3)(1)) Aayakar Bhavan, M.K. Road, ) Mumbai - 400 020. ) 2. Principal Commissioner of Income Tax-1, ) Aayakar Bhavan, M.K. Road, ) Mumbai - 400 020. ) 3. National Faceless Assessment Centre, Delhi,) National Faceless Assessment Centre, ) New Delhi – 110 003. ) 4. Union of India ) Through the Secretary, Ministry of Finance,) Government of India, North Block, ) New Delhi - 110 001. ) .. Respondents ______________________________________________________ Mr. J. D. Mistri, Senior Advocate a/w Mr. Harsh M. Kapadia for the petitioner. Mr. Suresh Kumar for the respondents. ______________________________________________________ CORAM M.S. Sonak & Jitendra Jain, JJ. RESERVED ON: 3 March 2025 PRONOUNCED ON: 7 March 2025 JUDGMENT (Per Jitendra Jain, J):- 2 1.WP.2486.22(J).docx 1. Rule. The Rule is made returnable immediately at the request of and with the consent of the learned counsel for the parties. 2. This Petition challenges re-assessment notice under Section 148 of the Income-tax Act, 1961 (the Act) dated 30 March 2021 for the assessment year (AY) 2014-2015 and the re-assessment order passed pursuant thereto dated 28 March 2022. Brief Facts : 3. The petitioner filed its return of income u/s 139(1) of the Act on 24 November 2014 which was subsequently revised on two occasions namely on 17 March 2016 and 25 March 2016 which was further modified on 29 November 2016. I