TMI Blog2024 (2) TMI 1207X X X X Extracts X X X X X X X X Extracts X X X X ..... : Mr. Harsh Makhija, Advocate For the Respondents: Mr. Aakarsh Srivastava, Senior Panel Counsel with Mr. Vaibhav Gupta and Mr. Shubham Goel, Advocate for UOI Ms. Shaguftha Hameed, Mr. Prateek Badhwar, Ms. Samridhi Vats, Advocates for Mr. Rajeev Aggarwal, ASC JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Issue notice. Notice is accepted by learned counsel appearing for the respondent. With the co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the taxpayer has nothing to say in the matter. 6. The observation in the impugned order dated 31.12.2023 is not sustainable for the reasons that the reply filed by the petitioner is a detailed reply. 7. The proper officer had to at least consider the reply on merits and then form an opinion whether the explanation was sufficient or not. He merely held that no proper reply/explanation has been ..... X X X X Extracts X X X X X X X X Extracts X X X X
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