Jaganathan Bhaarath v. ACIT (2024) 297 Taxman 461 (Mad.)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-e. filing portal did not include a tab for submission of an online reply-Matter remanded back for consideration. [S. 148, 148A(b), 148A(d), Art. 226]

Assessee submitted reply to said notice physically contending that e-filing portal did not include a tab for submission of an online reply Order under section 148A(d) and consequent notice under section 148 was passed on ground that assessee did not submit a reply to notice. On writ the Court held that since reply submitted by assessee bore acknowledgement of Assessing Officer, order passed to effect that assessee did not file reply was to be quashed and, matter is  remanded back for consideration of objections of assessee.Matter remanded. (AY. 2013-14)