TMI Blog2022 (10) TMI 235X X X X Extracts X X X X X X X X Extracts X X X X ..... tated that since the Petitioner already knew about the issue, he should have explained the source of the purchase of the property in its reply - HELD THAT:- Revenue reiterates that though there was factual mistake in the notice issued u/s 148A(b) of the Act, yet as the petitioner knew the factual issue, he should have explained the source of purchase of property. After hearing learned counsel f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in its reply shall also explain the source of fund for purchase of property. The Assessing Officer shall pass the order under Section 148A(d) of the Act in accordance with law. - W.P.(C) 13171/2022 & CM APPLs.39885-39886/2022 - - - Dated:- 9-9-2022 - HON'BLE MR. JUSTICE MANMOHAN AND HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA Petitioner: Mr.Amit Kaushik, Advocate. Respond ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... une, 2022 to the said letter, wherein it was submitted that the Petitioner had not sold any property during the year under consideration but property had been registered in the petitioner s favour worth Rs.8,19,61,960/-and that the Petitioner had filed multiple replies to the notices issued under Section 133(6) of the Act by the Intelligence and Criminal Investigation Unit of the Tax Department in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stake in the notice issued under Section 148A(b) of the Act, yet as the petitioner knew the factual issue, he should have explained the source of purchase of property. 5. After hearing learned counsel for the parties, this Court is of the view that there has been clear violation of principles of natural justice, inasmuch as, the respondent never asked the petitioner to explain the source of pur ..... X X X X Extracts X X X X X X X X Extracts X X X X
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