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TMI Blog2024 (7) TMI 905X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 144B - HELD THAT:- Faceless Assessment Unit, after taking into consideration all aspects, inter alia, including explanation given by the petitioner no.1, had concluded that no adverse inference can be drawn in the case and had accordingly accepted the income, as filed in the Income Tax Return as Rupees Zero, no demand on the basis thereof could have been raised by the respondents. Thus, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It is the petitioners case that sometimes on 17th March 2022 the petitioner no.1 was served with a notice under Section 148A(b) of the said Act calling upon the petitioner no.1 to furnish response in respect of the financial transactions made by the petitioner no.1 during the relevant financial year 2014-15. The said proceedings ultimately culminated in an order dated 4th April 2022 issued under S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssment unit had categorically recorded that in view of the disclosure made by the petitioner no.1 and the explanation offered, there is no adverse inference drawn in the case and the return filed by the assessees/petitioner no.1 is accepted. Consequentially, the recomputed return was assessed at Rupees Zero. 4. It, however, appears that despite assessing the recomputed income to be Rupees Zero und ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n this matter. 6. Today, Mr. Dudhoria, learned advocate appearing for the respondents acknowledges the fact that in the instant case the assessment order dated 19th March 2024 issued under Section 147 read with Section 144B of the said Act, had been passed by recomputing total income as per the Income Tax Return filed by the petitioner no.1 as Rupees Zero. He submits that by reasons of technical g ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n sheet appended to the demand notice is also contrary to the assessment order dated 19th March 2024. 8. In view thereof, to the aforesaid demand notice dated 19th March 2024 for the assessment year 2015-16, PAN AAAAN7255P cannot be sustained and the same is accordingly quashed. 9. With the above directions and observations the writ petition being WPA 11884 of 2024 is disposed of without any order ..... X X X X Extracts X X X X X X X X Extracts X X X X
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