Allowing the petition the Court held that transaction items mentioned in order under section 148A(d) not mentioned in notice. Non-application of mind by Assessing Officer and sanctioning authority Principal Chief Commissioner. Accordingly the order under section 148A(d) and notice under section 148 quashed and set aside.. (AY 2016-17)
Samiksha Gour v. ITO [2024] 162 taxmann.com 903 / (2025) 478 ITR 187 (Bom)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Share application money-Shell companies-Penny stock-Pendency of appeal-Second reassessment proceedings while first reassessment proceedings pending-Transaction items mentioned in order under section 148A(d) not mentioned in notice-Non-application of mind by Assessing Officer and sanctioning authority Principal Chief Commissioner-Order under section 148A(d) and notice under section 148 quashed and set aside [S. 147, 148, 148A(b),148A(d), 151, Art. 226]
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