Against the issue of notice under section 10(1) of the Act, the assessee filed the writ petition. Dismissing the petition the Court held that,  the settled proposition is that in construing fiscal statutes and in determining the tax liability, strict rules of interpretation will have to be followed without adding or importing significance beyond the language used in such statutes. In view of the scheme under section 10 and the express provisions of section 8(2) the contention of the assessee that the provisions of section 8 of the 2015 Act would indicate a distinct and separate enquiry on the “jurisdictional fact” from an enquiry contemplated under section 10 of the 2015 Act would be a contrived reading. Therefore, the Assessing Officer must necessarily decide on the “jurisdictional fact” whether the assessee could be called a beneficial owner of the specified undisclosed asset considering the material that the assessee produced and there would be sufficient opportunity to the assessee to produce further documents. That the question of issuance of notice under section 10(1) of the 2015 Act being beyond the period of thirty days, and therefore the need for approval from the concerned authority would have to be decided on the basis of paragraph 6 of the guidelines issued by the Central Board of Direct Taxes which made a distinction between information and intelligence. In so far as information is concerned, the guideline is categorical that it could be information received from other law enforcing agency (which would include the Income-tax authorities) unearthed during search or survey or other investigation. The notice was categorical that information in the assessee’s case was received on a reference by the Joint Commissioner. The contention that the Assessing Officer should be presumed to have had information of the transaction could not be drawn at this stage to truncate the enquiry. Therefore, it could not be opined that the notice was issued beyond thirty days from the date of information and therefore prior approval ought to have been obtained. It was a detailed notice and there were multiple references to different transactions between and amongst Romulus Assets  Ltd (RAL)  and other entities. The notice also referred to certain minutes of meetings and instances of payments with necessary documents illustrated. The transactions were multi-fold and when the assessee was yet to file a response and produce documents, accounts and evidence and the Assessing Officer was yet to consider those materials it could not be held that the notice lacked in material details or did not consider material circumstances, including the orders of the Tribunal. The notice under section 10(1) of the 2015 Act was sustainable. (AY 2022-23)