TMI Blog2023 (3) TMI 1118X X X X Extracts X X X X X X X X Extracts X X X X ..... ot been adhered to by not dealing with the rebuttal by the petitioner point-wise - HELD THAT:- It is not a case that the AO has not at all adhered to or complied with the formalities of SOP. The said impugned order has elaborate discussion on the point-wise rebuttal. It seems that petitioner is not satisfied with the reasoning and the way of dealing points of the rebuttal by the petitioner. There ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not act as an appellate authority over such assessment order and substitute the reasoning and finding by an Assessing Officer with its own finding and reasoning. WP dismissed. - WPA 1306 of 2023 - - - Dated:- 30-1-2023 - Md. Nizamuddin, J. For the Petitioner : Mr. Abhrotosh Mazumder, Sr. Adv., Mr. Avra Mazumder, Mr. Ramesh Patodia, Ms. Megha Agarwal, Mr. Kausheyo Roy, Mr. Suman Bhowmik, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It seems that petitioner is not satisfied with the reasoning and the way of dealing points of the rebuttal by the petitioner. There is a difference between not proper dealing or sufficiently dealing with no reasoning or not dealing at all. In this case it appears that petitioner is not satisfied with the reasoning and finding recorded by the Assessing Officer in the impugned assessment order. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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