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2024 (10) TMI 91

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..... n abject failure on the part of the AO to either examine or consider the objections that were submitted. AO has for reasons unknown and unfathomable merely observed that the response of the petitioner has not been found to be maintainable. The order u/s 148A(d) as well as the consequential notice u/s 148 of the Act are thus liable to be set aside on this short score alone. We, accordingly, allow t .....

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..... e Tax Act, 1961 for the A. Y. 2020-2021 issued by the Respondent No. 1 to the petitioner. B. Issue an appropriate Writ, Order or Directions in the nature of Certiorari or Mandamus thereby setting aside the order dated 10.04.2024 under section 148A(d) of the income tax act, 1961 for the A.Y. 2020-2021 issued by the Respondent No. 1 to the petitioner. C. Pass any other appropriate relief, which this .....

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..... le information is explicit and clearly suggests that during the relevant previous year, the assessee had income chargeable to tax and has escaped assessment. As the information was self-sufficient, it was considered that further enquiries u/s 148A(a) of the I.T. Act were not required. Therefore, in accordance with section 148A(b) of the I.T. Act, an opportunity of being heard was provided to the a .....

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..... properties is not fully matched in absence of complete documents. Thus, reply filed has not been found satisfactory and acceptable. 5. It is thus manifest that there has been an abject failure on the part of the AO to either examine or consider the objections that were submitted. The AO has for reasons unknown and unfathomable merely observed that the response of the petitioner has not been found .....

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