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TMI Blog2025 (4) TMI 299X X X X Extracts X X X X X X X X Extracts X X X X ..... PER M. S. SONAK, J 1. Heard learned Counsel for the parties. 2. Rule. The Rule is made returnable forthwith at the request and with the consent of the learned counsel for the parties. 3. This Petition concerns the Assessment Year 2016-2017. The Petitioner challenges an impugned notice dated 30 March 2021 (Exhibit "A"), impugned order dated 2 February 2022 (Exhibit "B"), and impugned notice und ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er 2021. The Petitioner had, inter alia, contended that the reasons to believe, in this case, was not that of the AO; absence of fresh tangible material; a case of change of opinion; an additional CIT's sanction was mechanical and without any application of mind. 7. The Faceless Centre has rejected the objections vide order dated by simply making the following observations: "The reasons giving r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income-tax Act, 1961 is in order." 9. In the peculiar facts of this case, we must record that the above is hardly a way the objections of the Petitioner were required to be considered and disposed of. Except for summarising the Petitioner's objections, such objections are not considered. The impugned order contains no reasons and records only conclusions. Simply stating that the AO, who iss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld also be considered and disposed of. 11. If the Jurisdictional Assessing Officer's order is averse to the Petitioner, the same should not be given effect for four weeks from the date of its communication. 12. All contentions of all parties are left open. 13. The Rule is made absolute in the above terms without any cost of order. 14. All concerned to act on an authenticated copy of this order ..... X X X X Extracts X X X X X X X X Extracts X X X X
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