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TMI Blog2023 (2) TMI 969X X X X Extracts X X X X X X X X Extracts X X X X ..... ioned is Rs. 42,18,000/-. This is despite the petitioner informing the Assessing Officer (AO) via communication dated 06.06.2022, that there is a discrepancy between what is stated in the Section 148A(b) notice and the input received from the insight portal. According to us, there has been no application of mind, and therefore, the impugned order and notices are set aside. AO will have liberty ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - 27-1-2023 - HON'BLE MR JUSTICE RAJIV SHAKDHER AND HON'BLE MS JUSTICE TARA VITASTA GANJU Petitioner: Mr Sumit Lalchandani, Adv. And Mr Salil Kapoor. Respondents: Mr Ruchir Bhatia, Sr. Standing Counsel. ORDER RAJIV SHAKDHER, J (ORAL): CM Appl.3917/2023 1. Allowed, subject to just exceptions. W.P.(C) 1013/2023 CM Appl.3916/2023 [Application filed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the impugned notices and the order concern Assessment Year (AY) 2016-2017. 6. We may note, that the petitioner has also laid challenge to the instructions dated 11.05.2022 issued by the Central Board of Direct Taxes (CBDT). 7. Counsel for the petitioner says, that at this juncture, he does not wish to press this particular prayer. 8. Concededly, even according to Mr Bhatia, there is a dis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d passed an order under Section148A(d) of the Act, in which the amount of the escaped income has been scaled down to Rs 42,18,000/-. 12. According to us, there has been no application of mind, and therefore, the impugned order and notices are set aside. 13. The AO will have liberty to take the next steps in the matter, albeit, as per law. 14. Needless to state, if any such steps are taken ..... X X X X Extracts X X X X X X X X Extracts X X X X
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