Pointing out the notifications issued on March 31 and April 27, Panneerselvam challenged the order contending that the reassessment was done under the old provision that expired on April 1, and sought the assessment to be done under the amended provision.
“It is unclear as to what the period of limitation would be and whether notices issued subsequent to March 31 would require a different procedure to be followed than the procedure followed prior to April 1,” submitted senior counsel Vijay Narayan who appeared for Panneerselvam. However, I-T counsel AP Srinivas said that it was clearly stipulated that searches initiated before April 1 would continue to be governed by the old procedure.
Recording the submissions, the court held that though the matter required consideration as a case was made out, no interim order was required immediately. The hearing was then adjourned to December 8.
The matter pertains to the raids conducted on the premises of businessman J Shekar Reddy and others in T Nagar in December 2016. After seizing documents, including diaries, the department reassessed Panneerselvam’s income based on the mentions found in them and issued notices to him on seeking Rs 20 lakh for 2015-16 financial year and Rs 82.12 crore for 2017-18. But Panneerselvam moved the court challenging the I-T assessment and sought it to be quashed.
The department had also issued notices to former chief minister Edappadi K Palaniswami and 12 former ministers in connection with the seizure of diaries.