Browntape Technologies Pvt. Ltd. v. ACIT (2025) 482 ITR 789 (Bom) (Gao)(HC)

S. 147: Reassessment-Order passed without considering objections of assessee-Not valid-Order and notice quashed and set aside. [S. 148, Art. 226]

Held that acknowledgement receipts had been generated by the system and, in the absence of any doubt about the authenticity of such acknowledgement receipts, there was no case made out to doubt the assessee’s statement made on oath that the objections were filed not once but twice to the notices issued by the respondents. Accordingly, the order dated July 29, 2022 was made without considering the assessee’s objections and based on the improper premise that it was the assessee who had failed to file the objections. On this short ground, the order dated July 29, 2022 is set aside (AY.  2016-17)

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