2019 (12) TMI 869

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... was issued to the petitioner. In such circumstances, this court is of the considered opinion that the order impugned dated 26.06.2019 at Annexure A shall be treated as show-cause notice. The petitioner shall put forth his reply/objections within a period of two weeks from the date of receipt of the certified copy of the order. On receipt of such reply/objections, the respondent-authority sha .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... hort). 3. The petitioner is engaged in the business of bar and restaurant in the name and style of Aruna Bar and Restaurant . For the assessment year 2017-18, the petitioner had filed the return of income declaring the tax liability of ₹ 4,14,890/-. The respondent-authority has issued a notice under Section 133(6) of the Act to the Bankers of the petitioner calling upon them .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ation, ₹ 3,79,70,200/- cannot be construed as the income of the petitioner. No reasonable opportunity was provided to the assesse to put forth the explanation. 5. The learned counsel for the Revenue justifying the order impugned submitted that the factual aspects in as much as the VAT returns and the tax liability to which the petitioner is subjected, cannot be adjudicated in .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X