TMI Blog2022 (1) TMI 1232X X X X Extracts X X X X X X X X Extracts X X X X ..... ner's has not offered tax under the head income from house property. Dr. Shivram states that the same issue was raised during the assessment proceedings as could be seen from Item No.16 in the annexure to notice dated 8th October, 2018, issued under Section 142(1) of the Act and petitioner has replied to, the same vide petitioner's letter dated 8th November, 2021. Dr. Shivram states that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Shivram, Senior Advocate, i/b Rahul Hakani For the Respondent : Mr. Suresh Kumar ORDER PC:- 1. Dr. Shivram for petitioner states that the notice under Section 148 of the Income Tax Act, 1961 ( the Act ) for Assessment Year 2016-2017 has been issued purely on change of opinion, which is not permissible in law. Dr. Shivram states that, for the reasons, reliance has been placed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mmercials Ltd. vs. Deputy Commissioner of Income-tax -2(1) (2014) 44 taxmann.com 304 (Bombay). submitted that once a query has been raised and it has been replied to, the Assessing Officer is deemed to have applied his mind and considered the same even if that issue has not been discussed in the assessment order. 2. Mr. Suresh Kumar requests the matter be taken up after a week so that he can ta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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