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2022 (1) TMI 1281 - HC - Income TaxReopening of assessment u/s 147 - statutory obligation of observing the formality of Section 148A not complied with - HELD THAT:- It is an admitted position and undeniable fact that in this case statutory formalities of Section 148A of the Income Tax has not been observed by the AO before issuing notice u/s 148 and the learned Counsel for the petitioners in support of his contention has relied on my own order passed in Bagaria Properties and Investments Private Limited & Anr. vs. Union of India & Ors. [2021 (8) TMI 788 - CALCUTTA HIGH COURT] which is on the same fact and same issue where Income Tax Authorities had not complied with statutory obligation of observing the formality of Section 148A of the Income Tax Act, 1961. We direct the respondents to file affidavit-in-opposition by 10th January, 2022. Petitioner to file reply thereto, if any, by 13th January, 2022. List the matter for hearing on 17th January, 2022.
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