Kiran Milapchand Jain (Smt.) v. Review Unit, Income-Tax Department (2025)472 ITR 644 (Karn)(HC)

S. 148A : Reassessment- Conducting inquiry, providing opportunity before issue of notice- Unable to file reply to initial notice within time granted owing to technical glitch on portal —Reply was filed prior passing of the order- Natural justice- Order is not valid. [S.148A(b), 148A(d), Art. 226]

Allowing the petition the Court held that the Assessing Officer committed an error in not considering the reply which was undisputedly submitted prior to the order and consequently, since the order was passed without providing sufficient or reasonable opportunity to the assessee it was violative of the principles of natural justice. The order passed under section 148A(d) of the Act is quashed.   (AY.2016-17)

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