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TMI Blog2024 (4) TMI 287X X X X Extracts X X X X X X X X Extracts X X X X ..... r Advocate with Mr. Prashanth Shivadass, Mr. Devashish Marwah, Mr. Rishabh and Mr. Sampath, Advocates For the Respondents: Mr. Rajiv Aggarwal, ASC with Ms. Samridhi Vats, Advocate JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 26.12.2023, whereby the impugned Show Cause Notice dated 25.09.2023, proposing a demand of Rs. 20,07,15,517.00 against the Petitioner has bee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onpayers. To the said Show Cause Notice, a detailed reply was furnished by the petitioner giving full disclosures under each of the heads. 4. The impugned order, however, after recording the narration, records that the reply uploaded by the taxpayer is incomplete, not duly supported by adequate documents, not clear and unsatisfactory. It merely states that "On the basis of reply uploaded by the t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ugned order dated 26.12.2023 is not sustainable for the reasons that the reply dated 19.10.2023 filed by the Petitioner is a detailed reply. Proper Officer had to at least consider the reply on merits and then form an opinion. He merely held that the reply is incomplete, not clear and unsatisfactory which ex-facie shows that Proper Officer has not applied his mind to the reply submitted by the pet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... timate to the petitioner details/documents, as maybe 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 peri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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