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2024 (7) TMI 1435

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..... ing of assessment - Non providing the reasons to assessee though requested - respondents, submits that the petitioner did not request for reasons through the ITBA portal, therefore, the request for reasons did not come to the notice of the AO - HELD THAT:- As prior to the amended regime being put it place with regard to re-assessment proceedings, by virtue of the order of the Hon'ble Supreme C .....

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..... by leaving it open to the respondents to initiate de novo proceedings in accordance with law. - THE HONOURABLE MR. JUSTICE SENTHILKUMAR RAMAMOORTHY For the Petitioner : Mr.S. Saravanakumaran for Mr. M. Velmurugan For the Respondents : Mr.R. S. Balaji , Senior Standing Counsel Mrs.S. Premalatha , Junior Standing Counsel ORDER An assessment order dated 30.03.2022 on best judgment basis is assaile .....

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..... ail ID of the petitioner's husband for and on behalf of the petitioner requesting for the reasons for reopening the assessment on the ground of alleged escaped income. By referring to the impugned order at paragraph 3 thereof, learned counsel pointed out that the assessing officer referred to the assessee's registered e-mail ID and that such e-mail ID is the same as the e-mail ID from whic .....

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..... eded to issue the assessment order on best judgment basis. 5. Even prior to the amended regime being put it place with regard to re-assessment proceedings, by virtue of the order of the Hon'ble Supreme Court in GKN Driveshafts, the Income-tax Department was under an obligation to provide reasons if requested for by the assessee concerned after filing the return of income pursuant to receiving .....

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