Commissioner Of Income Tax ... vs Genpact Consulting Singapore Pte Ltd on 11 December, 2024
11. We take note of an identical position which obtained in the case
of Genpact Luxembourg S.A.R.L. vs. Assistant Commissioner of
Income Tax, Circle 1(3)(1), International Taxation, New Delhi and
Anr.9 and which had assailed the initiation of Section 148
proceedings. Dealing with identical allegations which had come to be
levelled against that assessee, we had while allowing that writ petition
observed as follows: -