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TMI Blog2021 (11) TMI 574X X X X Extracts X X X X X X X X Extracts X X X X ..... to explain to the Assessing Officer voluminous documents, which were presented by the assessee at the time of assessment - HELD THAT:- Admittedly, the Income Tax Act is a Code by itself and it provides for hierarchy of remedies. The contention both before the learned Single Judge as well as before us is that the assessee did not have adequate opportunity to explain the voluminous documents. On the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ustice T.S.Sivagnanam And Honourable Mr.Justice Sathi Kumar Sukumara Kurup For the Appellant : Mr.G.Baskar For the Respondents : Mr.S.Prabhu Mukunth Arunkumar, JSC JUDGMENT T.S.SIVAGNANAM, J. We have heard Mr.G.Baskar, learned counsel appearing for the appellant and Mr.S.Prabhu Mukunth Arunkumar, learned Junior Standing Counsel accepting notice for the respondents. 2. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... initially, the assessment was dealt with by a different officer and subsequently, the file got transferred to the officer, who passed the assessment order dated 30.12.2010 and the said officer rushed through the entire matter and without affording opportunity to the assessee, the assessment has been completed. 7. The respondents filed a counter stating that not only notice was issued by the ea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le Judge as well as before us is that the assessee did not have adequate opportunity to explain the voluminous documents. On the other hand, the Assessing Officer would submit that adequate opportunity was granted and the assessee represented by their authorized representative was heard. 11. In any event, whether appreciation of the documents was done or not and whether there was sufficient opp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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