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2024 (12) TMI 823 - HC - Income TaxValidity of assessment order - findings given in the assessment order submits are self-contradictory as on the one hand the authority held that no reply has been furnished by the petitioner and on the next breath considered the reply dated 14.03.2024 in a cryptic manner - HELD THAT - The proper officer opined that no reply has been furnished and on the other hand considered the reply. The consideration is also cryptic. We find substance in the argument of the learned counsel for the petitioner that the reply and the documents filed therewith were not considered in proper perspective. There is no application of mind on the bank s confirmation letter and bank statement of Yashoda Nookaratnam. Thus reasons have not been given for not accepting the defence of the petitioner. The reasons are held to be heartbeat of conclusions. In M/s. Kranthi Associates (P) Ltd. v. Masood Ahmed Khan 2010 (9) TMI 886 - SUPREME COURT has emphasized the need of assigning reasons in administrative quasi-judicial and judicial orders. We are not inclined to relegate the petitioner to avail alternative remedy. The assessment order is set aside. The competent authority shall re-hear the petitioner and decide the matter afresh in accordance with law. It is made clear that this Court has not expressed any opinion on merits.
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