TMI Blog2024 (4) TMI 272X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the reply is not satisfactory nor any substantial documents were submitted by the taxpayer which ex-facie shows that Proper Officer has not applied his mind to the reply submitted by the Petitioner. The impugned order records the reply furnished by the Petitioner as incomplete, not supported by adequate documents, unclear and unsatisfactory. Proper Officer is directed to intimate to the petitioner if any details/documents, as may be required to be furnished by the petitioner. Pursuant to the intimation being given, petitioner shall furnish the requisite explanation and documents. Thereafter, the Proper Officer shall re-adjudicate the Show Cause Notice after giving an opportunity of personal hearing and shall pass a fresh speaking order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... payer is incomplete, not supported by adequate documents, unclear and unsatisfactory. It merely states that The taxpayer filed their reply. On scrutiny of the same, it has been observed that the same is not acceptable as incomplete, not duly supported by adequate documents, without proper justification and thus unable to clarify the issue. Since, the reply filed is not clear and satisfactory, the demand of tax and interest conveyed via DRC-O1 is confirmed. The Proper Officer has opined that the reply is incomplete, not supported by adequate documents, unclear and unsatisfactory. 4. Learned counsel for Petitioner submits that Petitioner had filed a detailed reply dated 23.10.2023, however, the impugned order dated 30.12.2023 does not take in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eply furnished by the Petitioner as incomplete, not supported by adequate documents, unclear and unsatisfactory. Proper Officer is directed to intimate to the petitioner if any details/documents, as may be required to be furnished by the petitioner. Pursuant to the intimation being given, petitioner shall furnish the requisite explanation and documents. Thereafter, the Proper Officer shall re-adjudicate the Show Cause Notice after giving an opportunity of personal hearing and shall pass a fresh speaking order in accordance with law within the period prescribed under Section 75(3) of the Act. 10. It is clarified that this Court has neither considered nor commented upon the merits of the contentions of either party. All rights and contentions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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