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TMI Blog2022 (10) TMI 854X X X X Extracts X X X X X X X X Extracts X X X X ..... ord, we do notice that there is acknowledgment of the fact that four documents were uploaded on the relevant portal on 6th April 2022, in regard to which no reference at all, had been made by the Assessing Officer in its order dated 16th April 2022. Without speculating as to what would be the result, if the AO had, in fact, considered the documents so uploaded, we are of the view that the document ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Jain a/w. Ms. Radha Halbe, Advocate for petitioner. Mr. Akhileshwar Sharma a/w. Ms. Shilpa Goel, Advocate for respondents. PC : 1. The petitioner challenges the order dated 16th April 2022 passed under section 148(A)(d) of the Income Tax Act, 1961 ( the Act ) as also the notice dated 16th April 2022 issued under section 148 of the Act relevant to the assessment year 2018-19. 2. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... documents on the Portal on 6th April 2022, which included a copy of the Sale Deed as also a copy of the petitioner s bank statement to show that the amount which is alleged to have escaped assessment was received by the petitioner through banking channels and also reflected in the bank statement. It is further stated that in reference to the Sale Deed, an amount of Rs.92,87,500/-, which is reflec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assed under section 148A(d) of the Act, both, on the face of it, are unsustainable. It is stated that had the documents been considered in their correct perspective, there would be no occasion for the Assessing Officer to issue the notice under section 148. 4. From the record, we do notice that there is acknowledgment of the fact that four documents were uploaded on the relevant portal on 6th A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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