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The HC quashed the Best Judgment Assessment order under section 144, finding it legally untenable as the Assessing Officer failed to properly consider the petitioner's voluminous reply to the show cause notice. While the AO claimed to have found the reply unsatisfactory, no reasons were provided for this conclusion. Following Supreme Court precedent in M/S SHUKLA & BROTHERS, the matter was remanded for a fresh de novo assessment. The AO must provide the petitioner with a hearing opportunity if requested, consider their submissions, and issue a reasoned order within 12 weeks of receiving the court's decision.
The HC quashed the Best Judgment Assessment order under section 144, finding it legally untenable as the Assessing Officer failed to properly consider the petitioner's voluminous reply to the show cause notice. While the AO claimed to have found the reply unsatisfactory, no reasons were provided for this conclusion. Following Supreme Court precedent in M/S SHUKLA & BROTHERS, the matter was remanded for a fresh de novo assessment. The AO must provide the petitioner with a hearing opportunity if requested, consider their submissions, and issue a reasoned order within 12 weeks of receiving the court's decision.
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