9911796707
TMI Blog2023 (6) TMI 1353X X X X Extracts X X X X X X X X Extracts X X X X ..... g heard was provided to the petitioner along with the copy of information and material relied upon and the assessee petitioner was asked to explain as to why the aforesaid transaction should not be treated as income chargeable to tax which is an escaped assessment. It also appears from the aforesaid impugned order that notice along with annexure was duly served upon the assessee petitioner thro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng of the order u/s 148A(d) to make out any case if he has in his favour subsequent to the notice u/s 148 of the Act before passing of the final assessment order under Section 147 of the Act. Thus order u/s 148A(d) of the Act is neither final assessment order nor any demand arises out of the same and even if the order is passed under Section 147 of the Act that itself is also appealable under t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... heard was provided to the petitioner along with the copy of information and material relied upon and the assessee petitioner was asked to explain as to why the aforesaid transaction should not be treated as income chargeable to tax which is an escaped assessment. It also appears from the aforesaid impugned order that notice along with annexure was duly served upon the assessee petitioner through s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ample scope after passing of the order under Section 148A(d) of the Act to make out any case if he has in his favour subsequent to the notice under Section 148 of the Act before passing of the final assessment order under Section 147 of the Act. Furthermore I am of the considered opinion that order under Section 148A(d) of the Act is neither final assessment order nor any demand arises out of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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