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TMI Blog2024 (5) TMI 827X X X X Extracts X X X X X X X X Extracts X X X X ..... lty - HELD THAT:- The observation in the impugned order dated 29.12.2023 is not sustainable for the reasons that the reply dated 25.10.2023 filed by the Petitioner is a detailed reply with supporting documents. 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 duly supported by adequate documents, unable to clarif ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Raja, SPC R-1/UOI. Mr. Rajeev Aggarwal, ASC with Mr. Prateek Badhwar and Ms. Shaguftha H. Badhwar, Advocates for R-2 to 5 JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 29.12.2023 whereby the impugned Show Cause Notice dated 25.09.2023 proposing a demand of Rs. 5,04,98,487.00/- against the petitioner had been disposed of and demand including penalty has been raised against ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ailed reply was furnished by the petitioner giving response under each of the heads with supporting documents. 4. The impugned order, however, after recording the narration records that the reply uploaded by the taxpayer is incomplete, unsatisfactory, not duly supported by adequate documents and unable to clarify the issue. It states that And whereas, the taxpayer had filed their reply in DRC-06, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated 25.10.2023 filed by the Petitioner is a detailed reply with supporting documents. 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 duly supported by adequate documents, unable to clarify the issue which ex-facie shows that Proper Officer has not applied his mind to the reply submitted by the petitioner. 6. F ..... X X X X Extracts X X X X X X X X Extracts X X X X
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