Income Assessment Order Quashed; Authority to Reconsider with Full Review and Personal Hearing Option for 2019-2020.

The HC quashed the order and notice dated 13.04.2023 regarding escaped income assessment for the Assessment Year 2019-2020. The court found that the authority failed to consider the petitioner's initial and supplementary replies, along with the submitted documents. The HC directed the authority to reconsider the matter, ensuring that all submissions are reviewed and a reasoned order is provided. The authority must offer the petitioner a personal hearing if requested and promptly communicate the decision, thereby resolving the petition and related applications.

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Issues involved:
The judgment involves the assessment of escaped income/transactions in the Assessment Year 2019-2020 based on an order and notice issued to the petitioner.

Assessment of Escaped Income/Transactions:
The petitioner challenged an order and notice concluding that income/transactions amounting to Rs. 2,73,28,43,663/- had escaped assessment in the Assessment Year 2019-2020. The petitioner contended that the details provided in response, which were already accounted for in the company's Books of Account, were not considered by the authority. Additionally, a supplementary reply filed by the petitioner was allegedly not taken into account. The respondents argued that the petitioner's reply had been considered, and the supplementary reply filed on 03.04.2023 was not received. However, evidence submitted by the respondents themselves contradicted this claim, showing that the reply was indeed filed on the specified date. The court observed that the authority failed to consider the replies and documents submitted by the petitioner, leading to a lack of reasoning for the conclusion that income had escaped assessment.

Judgment and Order:
The High Court quashed the order and notice dated 13.04.2023, directing the concerned authority to reconsider the matter. The court instructed the authority to take into account both the initial and supplementary replies along with the accompanying documents. The authority was mandated to provide a speaking and reasoned order after giving the petitioner an opportunity for a personal hearing if requested. The court ordered prompt communication of the decision to the petitioner, thereby disposing of the petition and any related applications.

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