Shree Shakambhari Udyog v. CIT (2025) 344 CTR 612 / 249 DTR 297 / 173 taxmann.com 955 (Pat)(HC) Editorial: SLP rejected-Shree Shakambhari Udyog Partnership Firm v. CIT (2025) 306 Taxman 339 / 479 ITR 238 (SC)

S. 147 : Reassessment-Information-Computer generated DIN-AO examined the information and transaction documents received from the complainant after giving opportunity of hearing to the assessee-Writ to quash proceedings dismissed. [S. 143(3), 143(3A), 148, Art. 226]

The assessment order was initially issued without a Document Identification Number (DIN), but the defect was subsequently cured on the same date by issuance of a digitally signed communication containing a computer generated DIN. The reassessment for AY 2017–18 was based on information and voluminous transaction documents furnished by a complainant (a partner of the assessee-firm), which were supplied to the assessee along with an opportunity to respond. The AO examined the materials and found that the assessee failed to substantiate how undisclosed sales of various products were accounted for in the books. Since the impugned order was not based on any statement or examination of the complainant, there was no requirement of cross-examination and Andaman Timber Industries v. CCE (2015) 281 CTR 241 (SC))/ (2016) 15SCC 785,was distinguished. The High Court held that no jurisdictional error was made out and declined to interfere in writ jurisdiction, leaving the assessee to pursue statutory appellate remedies. (AY. 2017–18)

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