9911796707
TMI Blog2023 (6) TMI 822X X X X Extracts X X X X X X X X Extracts X X X X ..... ttedly, no opportunity of personal hearing was granted to the assessee. In the order passed u/s 148A(d) there is a reference to certain transactions done by two companies. Admittedly, in the show cause notice there was no such allegation concerning these two companies qua the appellant/assessee. Also hearing was not fixed by the AO on 29.03.2022. But the show cause notice states that the e-r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the respondent under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as the said Act for brevity). The order was on the ground of violation of principles of natural justice. 2. The learned Writ Court declined to interfere with the said order on the ground that the appellant can raise all issues in the re-assessment proceedings. 3. Aggrieved by such order, the appel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 48A(d) there is a reference to certain transactions done by two companies, namely, M/s. Devyansh Dealcom Ptrivate Limited and M/s. Eastern Sales India. 7. Admittedly, in the show cause notice there was no such allegation concerning these two companies qua the appellant/assessee. Furthermore, we find that the hearing was not fixed by the Assessing Officer on 29.03.2022. But the show cause notice ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e matter is remanded back to the Assessing Officer for fresh consideration. The Assessing Officer is directed to furnish all relevant information concerning those two companies and other information wherein the assessee has been roped in and 15 days time should be granted to the assessee to submit short additional response. Thereafter an opportunity of personal hearing be granted and the fresh or ..... X X X X Extracts X X X X X X X X Extracts X X X X
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