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2022 (12) TMI 1459 - CALCUTTA HIGH COURTReopening of assessment - Validity of order passed u/s 148A - why two PAN numbers were obtained by the appellants / assessee? - HELD THAT:- Order passed u/s 148A(d) is a non-speaking order. Appellants had submitted a reply to the notice issued u/s 148A (b) wherein assessee has pointed out as to how and under what circumstances two PAN numbers were applied and the fact that one of the PAN numbers was surrendered, was also set out. AO should examine the correctness of the stand taken by the appellants, which according to the appellants, was an inadvertent mistake. As we are satisfied that the order is a non-speaking order, we are inclined to interfere with the same and remand the matter back to the assessing officer for fresh consideration and preserving the direction issued by the learned Single Bench directing the appellants to submit a representation. Appeal along with the connected application are disposed of by setting aside the order passed u/s 148A(d) of the Act and the matter stands remanded and restored to the file of the assessing officer.
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