Held, that the orders in question were unsustainable as the assessees had not been given adequate opportunity to respond to the notices issued under section 148A(b) of the Income-tax Act, 1961.Notice and order is quashed. The respondent is directed to pass a fresh order after giving a reasonable opportunity of hearing.
Shanmugasundaram Ravichandran v. ACIT (2024)460 ITR 247 /161 taxmann.com 212(Mad)(HC) Shanmugasundaram Rangasamy v.ACIT (2024)460 ITR 247 /161 taxmann.com 212(Mad)(HC) New Arcot Plywoods and Glasses v. ACIT (2024)460 ITR 247 /161 taxmann.com 212(Mad)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-No adequate opportunity to respond to notice-Notice of reassessment is quashed-Opportunity to respond the notice. [S. 148, 148A(b), Art. 226]