Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2021 (10) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (10) TMI 1287 - HC - Income TaxReopening of assessment u/s 147 - documents satisfactorily to explain the deposits or not shall be set out in the assessment order when it is made de novo - HELD THAT:- The case on hand is a case of non-consideration of support materials and not giving any reason as to why reply is unacceptable, leading to conclusion that the deposits have not been satisfactorily explained. Respondent may have considered, as contended by learned Revenue counsel, but the point remains that it could have been set out if not eloquently articulated in the impugned order as already delineated to supra. Considering the unique facts and circumstances of the case as a one off matter, captioned writ petition is sent back to respondent. Impugned order dated 28.09.2021 bearing reference DIN & Documen is set aside solely for the purpose of facilitating the respondent to redo the assessment by considering what according to writ petitioner inter-alia support affidavit - The sequitur to the above limb is, though obvious, it is made clear that this Court has not expressed any view or opinion on the merits of the matter.
|