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TMI Blog2013 (2) TMI 599X X X X Extracts X X X X X X X X Extracts X X X X ..... Proxy for Mr Abhishek Maratha, Sr. Standing Counsel. JUDGMENT BADAR DURREZ AHMED, J (ORAL) This writ petition is directed against the notice dated 30.08.2011 issued by the respondent under section 148 of the Income Tax Act, 1961 (hereinafter referred to as „the said Act‟) pertaining to the assessment year 2007-08. It is also directed against the order dated 28.01.2013 whereby th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s perhaps applied by the respondent to several such cases. In order to appreciate this fact we are reproducing the paragraph 5.7 herein below: - "5.7 In this case, the belief of the AO has been held in good faith and not on the basis of any rumour. In fact the reasons for issue of notice existed at the time of issue of notice and the reasons are genuine. They were in fact communicated to the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nse to the same, assessee has submitted written submission dated 27.09.2011 wherein the assessee submitted that the notice is illegal and without jurisdiction. We object the reassessment proceedings. The return already filed by u/s 139 for A Y 2007-08 may please be treated as return filed in pursuance of the notice now received. Further, it was also requested to enable us to make objections both o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bmission." It is apparent on going through the above extract that the respondent has not even bothered to change the words such as "we", "us", etc. which the petitioner had used in its objections/ reply. This shows that the respondent had not even applied his mind and not even bothered to correct the contents of paragraph 2 so as to put it into second person or third person in the grammatic sense ..... X X X X Extracts X X X X X X X X Extracts X X X X
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