2023 (7) TMI 1353

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ourt: Heard learned advocates appearing for the parties. By this writ petition, petitioner has challenged the impugned assessment order under Section 147 of the Income Tax Act, 1961, dated 31st May, 2023 relating to assessment year 2014-15 on the ground that its objection to the notice under Section 148A(b) of the Act was not properly considered and discussed in the order under Section 148A(d) of .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... assessing officer in the impugned assessment order which according to him is not sufficient. Mr. Bag has relied on a judgment of the Hon'ble Delhi High Court in the case of "SABH Infrastructure Ltd. vs. Assistant Commissioner of Income Tax" reported in (2018) 99 taxmann.com 409 (Delhi). I have considered the said judgment where the issue was relating to the notice under Section 148 of the Income T .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... tled principles of law that the Writ Court cannot act as an assessing officer or an appellate authority to scrutinise the facts and findings based on evidence by the assessing officer in the final assessment order which is an appealable order and to substitute with its own findings and reasonings. This is not a case where the assessment order has been passed by an authority having inherent lack of .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X