TMI Blog2022 (4) TMI 42X X X X Extracts X X X X X X X X Extracts X X X X ..... I. T. Act. In our view, there are no reasons recorded by the respondent No. 3 in the impugned order. Various objections raised by the petitioner are required to be answered by sufficient and cogent reasons. The respondent No. 3 has not given any reasons while dealing with the objection and passing the impugned order. This Court in a case of Tata Capital Financial Services Limited [ 2022 (2) TMI 1093 - BOMBAY HIGH COURT] after adverting to various judgments of various Courts including the judgment of the Hon ble Supreme Court in a case of Commissioner of Income Tax Vs. Vasisth Chay Vyapar Ltd. [ 2018 (3) TMI 56 - SUPREME COURT] has formulated guidelines to be followed by the revenue while dealing with the objection raised by the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dated 01.03.2022 passed by the respondent No. 3 thereby rejecting the objection filed by the petitioner. 3. On 28th March, 2018, the petitioner filed his return of income tax for the assessment year 2016-2017. On 31.03.2021, the respondent No. 2 issued notice U/Sec. 148 of the I. T. Act to the petitioner for reassessment of the assessment year 2016- 2017. On 01.04.2021 Finance Act, 2021 came into force and entire mechanism of reopening of assessment U/Sec. 147 to 151 of the Income Tax Act has been changed. 4. The respondent No. 2 supplied the copy of the reasons recorded before issuance of the impugned notice to the petitioner. On 24.02.2022 the petitioner filed objection to the reasons recorded and specifically raised objection rega ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ncome Tax Circle 1(3)(1) and others in Writ Petition No. 546 of 2022 and more particularly paragraph No. 8. This Court in the said judgment has formulated various guidelines to be followed by the assessing officer while dealing with the objections raised by the assessee. It is held that while communicating the reason for re-opening the assessment, a copy of the standard form/request sent by the Assessing Officer for obtaining approval of the Superior Officer should itself be provided to the assessee. He submits that, this Court has categorically held that the order disposing the objections should deal with each objections and give proper reasons for the conclusion. 8. Mr. Alok Sharma, the learned counsel for respondents on the other ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssistant Commissioner of Income Tax Circle 1(3)(1) and others (supra) after adverting to various judgments of various Courts including the judgment of the Hon ble Supreme Court in a case of Commissioner of Income Tax Vs. Vasisth Chay Vyapar Ltd. reported in [2019] 410 ITR 244 (SC) has formulated guidelines to be followed by the revenue while dealing with the objection raised by the assessee to the reasons furnished by the Assessing Officer. It is held by this Court that, if the reasons make reference to any other document or a letter or a report, such document or letter or report should be enclosed to the reasons. The order disposing the objections should deal with each objections and give proper reasons for the conclusion. In our view, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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