Court defers Writ Petition challenging reassessment proceedings for Assessment Year 2013-2014

The court deferred the Writ Petition challenging reassessment proceedings for Assessment Year 2013-2014. The petitioner contested a notice and order related to the reassessment, citing discrepancies in scrutiny outcomes for various years. The respondent agreed to withhold implementation pending the First Appellate Authority's decision on the 2014-2015 assessment order. The court accepted this undertaking, delaying further action until the Authority's decision was on record.

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Issues:
Reassessment proceedings for Assessment Year 2013-2014 challenged based on original return of income filed in 2013, existence of arrangement since 1994, scrutiny for multiple years with varying outcomes, challenge to order of assessment for 2014-2015 pending before First Appellate Authority.

Analysis:
The petitioner challenged a notice dated 23rd March 2018 and an order dated 24th August 2018 regarding reassessment proceedings for Assessment Year 2013-2014. The original return of income was filed in 2013, with the Assessing Officer referring to an arrangement in existence since 1994. While no addition was made for Assessment Year 2011-2012 and the assessee's explanation was accepted, scrutiny for subsequent years including 2013-2014 resulted in varying outcomes. Notably, the issue subject to the writ petition was raised for the first time in the order of assessment for 2014-2015, which is currently being challenged before the First Appellate Authority.

The respondents, through Mr. Charanjeet Chanderpal, agreed that the impugned notice and order would not be implemented until the First Appellate Authority hears and disposes of the pending appeal regarding the order of assessment for 2014-2015. This statement was accepted by the court as an undertaking. Consequently, the Writ Petition was deferred pending the placement of the First Appellate Authority's order on record by Mr. Charanjeet Chanderpal.

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