9911796707
TMI Blog2020 (1) TMI 733X X X X Extracts X X X X X X X X Extracts X X X X ..... counsel for the parties. 2. By this Petition, the Petitioner challenges the notice issued under Section 148 of the Income Tax Act dated 29 March 2019 and the order dated 26 September 2019 disposing of the petitioner's objections. By the impugned notice, the assessment for the year 2012-13 is sought to be reopened. 3. The Petitioner a salaried employee, filed his return of Income on 30 September ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the amount of Rs. 3,86,06,825/- is stated to have been received by the Petitioner which is entirely incorrect. Also the Respondent No.1 has proceeded on the basis that the Petitioner had purchased the property at Rs. 3,45,07,665/- and made investment of Rs. 40,99,160/- during the relevant assessment year. He submitted that in the objections filed, the Petitioner had pointed out that an amount of R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... facts have been clearly stated and the contentions of the Petitioner would be considered in the reassessment proceedings. Learned counsel for the Respondent relied upon the order passed in the Writ Petition No. 2164 of 2019 in Belazio Construction Private Limited vs. Income-tax Officer, Ward-12(1) (3), where this Court has not interfered with the reassessment notice in case where there was intimat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted on then it is stated that earlier no documents could be examined because it is the case of intimation under Section 143(1) of the Act, then the Assessing Officer reproduced the paragraphs regarding what is meant by "reasons to believe" and passed the order. In view of the fact that there is absolutely no application of mind whatsoever while disposing of the objections to the factual errors and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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