The assessee challenged the issue of notice u/s 148 of the Act and order disposing the objection. Allowing the petition the Court held that the Assessing Officer had to pass a speaking order taking into consideration the objections raised by the assessee. The cryptic manner of dealing without any semblance of reasons necessitated a remand. (AY.2013-14)
Shilp Realty Pvt. Ltd. v. ITO (2021) 439 ITR 478 / (2022) 284 Taxman 428 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-Objections to notice-Order disposing the objections must be passed by passing speaking order-Order disposing the objection was set aside. [S. 148, Art. 226]