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2022 (3) TMI 725 - GUJARAT HIGH COURTReopening of assessment u/s 147 - objections against the reasons for reopening - HELD THAT:- Bare reading of the relevant extract of web page of the portal indicates about the attachment annexed with the communication dated 10.06.2021, more particularly, under the column view other action, there is reference to view attach document file. The said document is suggestive of the fact that in fact the document in the nature of attachment was very much available on the Income Tax Business Application portal - without going into the aforesaid controversy of service of reasons recorded by the Assessing Officer seeking reopening of the assessment under Section 147 to balance equity we find it appropriate to relegate the writ applicant to submit it’s objections along with necessary documents, if any, which the writ applicant may propose to rely, in response to the reasons being produced before this Court. Writ applicant is permitted to approach the respondent Authority to submit the objections against the reasons for reopening of the relevant A.Y. under consideration with necessary documents, if any, within a period of two weeks from the date of receipt of the copy of this order. The writ applicant is at liberty to take all legal contentions as may be permissible in law. On receipt of such objections along with documents, if any, the respondent Authority is hereby directed to look into the matter and take decision in accordance with law. We clarify that even otherwise we have not gone into merits of the legality and validity of the impugned notice.
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