2019 (6) TMI 355

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....titioner has challenged the provisional attachment order dated 27.12.2018 passed under Section 281B as well as the Assessment order dated 28.12.2018 passed under Section 143(3) and the consequential demand notice dated 28.12.2018 under Section 156 of the Income Tax Act, 1961 ('Act' for short). 2. The petitioner is a company engaged in the business of development of immovable properties, formati....

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.... and the PAN numbers of the persons to whom the payments were made. Ignoring the same, the Assessing Officer has observed that no addresses and PAN numbers have been furnished by the assessee except the names in support of the development expenses and direct expenses. The same discloses the non-application of mind by the Assessing Officer. It is contended that immediately after passing of the orde....

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.... the assessment proceedings, extension of the said order is ordinarily not contemplated. Hence, the challenge made to the said order does not survive for consideration.   5. Having heard the learned counsel appearing for the parties and perusing the material on record, this Court is of the considered opinion that there is some force in the arguments advanced by the learned counsel for the ....