2023 (8) TMI 1427

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..... ference between non-consideration of the objection of petitioner/assessee and consideration of objection according to the petitioner is not being satisfactory - HELD THAT:- As in this case assessing officer has passed the impugned order by making detailed discussion and by a speaking order based on facts and evidence which cannot be substituted by this Court in exercise of constitutional writ jur .....

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..... llenged the impugned order under Section 148A(d) of the Income Tax Act, 1961 which was passed after compliance of all the statutory formalities like issuance of notice under Section 148A(b) of the Act, consideration of the response/reply to the said notice and even giving opportunity of personal hearing to the petitioner and consequently impugned notice under Section 148 of the Act has been issued .....

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..... e is a difference between non-consideration of the objection of petitioner/assessee and consideration of objection according to the petitioner is not being satisfactory. In this case assessing officer has passed the impugned order by making detailed discussion and by a speaking order based on facts and evidence which cannot be substituted by this Court in exercise of constitutional writ jurisdi .....

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