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TMI Blog2022 (2) TMI 594X X X X Extracts X X X X X X X X Extracts X X X X ..... reasons assigned by the Assessing Officer for reopening of the assessment for the relevant year are factually incorrect. In column No.8 of the same, we find reference of ₹ 52 Lakh towards full value of consideration. Although Mr. Bhatt tried to say something as regards the cost of acquisition with indexation, yet we are of the view that factually there is no foundation for the Revenue to reo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g reliefs: a) To quash and set aside the notice u/s. 148, dated 31.03.2021 for A.Y. 2016-17 at Annexure A; b) pending admission, hearing and final disposal of this petition, this Hon ble Court may kindly be pleased to stay and suspend operation and implementation of notice u/s. 148, dated 31.03.2021 for A.Y. 2016-17 at Annexure-A; c) Any other and further relief, which is just and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer, it has been stated that the assessee had not shown the sale consideration of ₹ 52 Lakh and thereby had failed to offer the same for tax in the return of income filed for the year under consideration. 3. The assessee filed his objections vide letter dated 27th July 2021 pointing out that the reasons assigned for the reopening is factually incorrect. 4. The objections ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... In column No.8 of the same, we find reference of ₹ 52 Lakh towards full value of consideration. Although Mr. Bhatt tried to say something as regards the cost of acquisition with indexation, yet we are of the view that factually there is no foundation for the Revenue to reopen the assessment on the ground as alleged in the reasons assigned to the writ applicant assessee. 7. In view of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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