9911796707
TMI Blog2024 (6) TMI 574X X X X Extracts X X X X X X X X Extracts X X X X ..... count from M/s Olivia Tradelinks India Pvt. Ltd. The other receipts with respect to which notice was issued are not disputed by the revenue. To that extent, the explanation furnished by the petitioner has found acceptance. Since, the petitioner was not confronted with the information that he had received cash deposits from M/s Agarwal Bullion, the petitioner was not granted opportunity to rebut the same. Seen in that light, it appears that due compliance of Section 148A has not been made, inasmuch as the notice issued to the petitioner u/s 148A (b) was not complete. In view of the fact that the petitioner has earlier faced scrutiny assessment for the same assessment year, wherein he claims to have disclosed all bank accounts with respect to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sment proceeding have been drawn up solely on the strength of information received with respect to deposits made by M/s Olivia Tradelinks India Pvt. Ltd. With respect to that, it is the petitioner's case that he had disputed any transaction performed by M/s Olivia Tradelinks India Pvt. Ltd. involving deposits of any cash by that entity in the petitioner's bank account. It was further case that all bank transactions of the petitioner had been examined in the scrutiny assessment proceeding for the A.Y. 2017-18. 5. Therefore, no material existed to suggest that any income has escaped assessment at the hands of the petitioner. 6. In such submissions made, we had made the following observations in our last order passed yesterday: 2. Limi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ived cash deposits from M/s Agarwal Bullion, the petitioner was not granted opportunity to rebut the same. Seen in that light, it appears that due compliance of Section 148A of the Act has not been made, inasmuch as the notice issued to the petitioner under Section 148A (b) of the Act dated 29.02.2024, was not complete. 10. In view of the fact that the petitioner has earlier faced scrutiny assessment for the same assessment year, wherein he claims to have disclosed all bank accounts with respect to which reassessment has been drawn, we consider it desirable that appropriate consideration be first made to the material aspects noted above before the fruitful reassessment proceeding may arise to the petitioner. 11. Accordingly, the order dated ..... X X X X Extracts X X X X X X X X Extracts X X X X
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