9911796707
TMI Blog2024 (6) TMI 1299X X X X Extracts X X X X X X X X Extracts X X X X ..... /- and not Rs. 85,84,660/- was submitted by the petitioner as an attachment to the reply dated 17.03.2024. Therefore, the impugned order is set aside and the matter is remanded for reconsideration. On perusal of the impugned assessment order, find no consideration of these contentions or documents. For these reasons, the impugned order is not sustainable - Assessee appeal allowed. - Hon'ble Mr. Justice Senthilkumar Ramamoorthy For the Petitioner : Mr.G. Varadhini Karthick For the Respondents : Dr. B. Ramaswamy, Senior Standing Counsel ORDER An assessment order dated 24.03.2024 is challenged on the ground of breach of principles of natural justice. 2. Upon the assessment of the petitioner being reopened by issuing an order under Sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... behalf of the respondent. By referring to the details of opportunities provided, as per the impugned order, he pointed out that the petitioner did not reply to several notices, including the notice under Section 148, the notice under Section 142(1), etc. By further submitting that the impugned order records that the petitioner has made cash deposits in the South Indian Bank of an aggregate amount of Rs. 85,84,660/-, he submits that the variations were confirmed because the petitioner did not satisfactorily explain the sources of such cash deposits. Since the impugned order is a reasoned order, he submits that no case is made out for interference by this Court. Learned counsel also submits that a personal hearing was offered to the petitione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he petitioner as an attachment to the reply dated 17.03.2024. 6. On perusal of the impugned assessment order, I find no consideration of these contentions or documents. For these reasons, the impugned order is not sustainable. 7. Therefore, the impugned order dated 24.03.2024 is set aside and the matter is remanded for reconsideration. The petitioner is permitted to submit additional documents, if any, within a maximum limit of 15 days from the date of receipt of a copy of this order. To enable the uploading thereof, the respondents are directed to take necessary action to provide access to the portal. The first respondent is directed to provide a reasonable opportunity, including a personal hearing, and thereafter issue a fresh assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X
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