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TMI Blog2022 (12) TMI 1459X X X X Extracts X X X X X X X X Extracts X X X X ..... the appellants / assessee? - HELD THAT:- Order passed u/s 148A(d) is a non-speaking order. Appellants had submitted a reply to the notice issued u/s 148A (b) wherein assessee has pointed out as to how and under what circumstances two PAN numbers were applied and the fact that one of the PAN numbers was surrendered, was also set out. AO should examine the correctness of the stand taken by the appel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AGNANAM, J. 1. This intra-Court appeal by the writ petitioners is directed against the order dated 28th November, 2022 in W.P.A. 19557 of 2022. By the said order, the writ petition stood disposed of by directing the appellants to file a representation before the assessing officer and explaining as to why two PAN numbers were obtained by the appellants / assessee. Till the disposal of the represen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3th April, 2022. Therefore, unless and until such order is set aside and the assessing officer is empowered to consider the matter afresh, the direction issued in the writ petition cannot be implemented. 4. We have perused the order dated 13th April, 2022 passed under Section 148A(d) of the Act and we find that the order to be a non-speaking order. The appellants had submitted a reply dated 28th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are disposed of by setting aside the order dated 13th April, 2022 passed under Section 148A(d) of the Act and the matter stands remanded and restored to the file of the assessing officer. The appellants are directed to submit a representation as directed by the learned Single Bench and the assessing officer on receipt of the representation shall afford an opportunity of personal hearing and consid ..... X X X X Extracts X X X X X X X X Extracts X X X X
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