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2024 (2) TMI 928 - HIMACHAL PRADESH HIGH COURTValidity of reassessment order/proceedings - as argued concerned authority has neither considered reply filed alongwith documents nor supplementary reply by the petitioner - HELD THAT:- Perusal of the impugned order indicates that though it has been recorded in it that reply of the assessee has been considered, but there is no reference with respect to reply and documents filed by the petitioner and there is no consideration with respect to supplementary/additional reply filed by the petitioner. So far as plea of the respondents that supplementary reply filed by the petitioner was not received by the concerned authority, is falsified from the document filed by the respondents themselves with their reply it has been clearly reflected that on 03.04.2023 reply from the assessee was filed. Thus it is apparently clear that concerned authority has neither considered reply filed alongwith documents nor supplementary reply filed by the petitioner. There is no speaking order assigning reason for conclusion arrived at that income/transactions has escaped assessment in the Assessment Year 2019-2020. Thus reopening order and notice are quashed and set aside and matter is relegated to the concerned authority for deciding afresh by taking into consideration reply as well as supplementary reply alongwith documents filed therewith, by passing a speaking and reasoned order.
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