2015 (8) TMI 925

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....ARAVIND, ADV., A/W SRI E.I.SANMATHI, ADV JUDGMENT This is an appeal filed by the assessee against the judgment and order dated 11.12.2014 passed by the learned Single Judge in W.P.No.14670/2014 whereby the petition challenging the notice under Section 148 of the Income Tax Act, 1961 (for short 'the Act') has been dismissed on the ground of availability of alternative remedy. 2. The brief ....

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.... said assessment year and issued questionnaire under Section 142(1) of the Act. 3. From the questionnaire issued to the assessee, it appears that re-opening of the assessment was on the basis of statement recorded by the Income Tax authorities of some other person, which statement was never furnished to the appellant. The appellant, thus, contends that besides the non-furnishing of the reasons ....

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.... return in response to the notice issued under Section 148 of the Act or on request of the assessee requesting that the return of income initially file d be treated as a return of income filed in response to such notice, the assessee is entitled to be furnished the reasons for such re-opening, which can also be challenged independently. Since such reasons had not been furnished to the appellant, e....