Allowing the petition the Court held that the Assessing Officer had referred to the assessee’s reply dated April 9, 2022 but there was no discussion as to the objection raised by the assessee in their reply. There was no discussion on the documents, which were placed by the assessee along with the reply with soft copies uploaded in the e-proceeding. The notice and order is set aside. (AY.2018-19)
Somnath Dealtrade Pvt. Ltd. v. UOI (2023)455 ITR 720 (2022) 143 taxmann.com 71 (Cal)(HC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Objections not considered-Notice and order is set aside. [S. 147, 148, 148A(b), 148A(d), Art. 226]