Nitinkumar v. JCIT. (2022) 443 ITR 411 (Bom.)(HC)

S. 147 : Reassessment-Duty of Assessing Officer-Rejection Of Objections must be by speaking order recording reasons for rejection of each objection-Matter remanded. [S. 148, 153C, Art. 226]

The Income-tax Officer rejected the objections filed by the assessee. On a writ the Court held that the order rejecting the objections raised by the assessee against reopening of the assessment under section 147 was in violation of the principles laid down by the court in the case of Tata Capital Financial Services Ltd. v. ACIT (2022)443 ITR 127 (Bom) (HC). The Assessing Officer has to consider each and every objection raised by the assessee against reopening of the assessment under section 147 of the Income-tax Act, 1961 and record reasons for his conclusion. The various objections raised by the assessee are required to be answered by sufficient and cogent reasons. (AY. 2016-17)