2024 (7) TMI 1435

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..... E MR. JUSTICE SENTHILKUMAR RAMAMOORTHY For the Petitioner : Mr.S. Saravanakumaran for Mr. M. Velmurugan For the Respondents : Mr.R. S. Balaji , Senior Standing Counsel Mrs.S. Premalatha , Junior Standing Counsel ORDER An assessment order dated 30.03.2022 on best judgment basis is assailed by the petitioner. The petitioner states that she had filed her original return of income for Assessme .....

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..... for reopening the assessment on the ground of alleged escaped income. By referring to the impugned order at paragraph 3 thereof, learned counsel pointed out that the assessing officer referred to the assessee's registered e-mail ID and that such e-mail ID is the same as the e-mail ID from which the request for reasons was provided. Since the assessment was reopened without adhering to principl .....

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..... put it place with regard to re-assessment proceedings, by virtue of the order of the Hon'ble Supreme Court in GKN Driveshafts, the Income-tax Department was under an obligation to provide reasons if requested for by the assessee concerned after filing the return of income pursuant to receiving notice under Section 148. In the case at hand, admittedly, the petitioner filed the return of income .....

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