2020 (1) TMI 733

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... and 2.   P.C.:- Heard learned counsel for the parties. 2. By this Petition, the Petitioner challenges the notice issued under Section 148 of the Income Tax Act dated 29 March 2019 and the order dated 26 September 2019 disposing of the petitioner's objections. By the impugned notice, the assessment for the year 2012-13 is sought to be reopened. 3. The Petitioner a salaried employe....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... factual errors in the Reasons supplied such as the amount of Rs. 3,86,06,825/- is stated to have been received by the Petitioner which is entirely incorrect. Also the Respondent No.1 has proceeded on the basis that the Petitioner had purchased the property at Rs. 3,45,07,665/- and made investment of Rs. 40,99,160/- during the relevant assessment year. He submitted that in the objections filed, th....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ted that in the Reasons given to the Petitioner the facts have been clearly stated and the contentions of the Petitioner would be considered in the reassessment proceedings. Learned counsel for the Respondent relied upon the order passed in the Writ Petition No. 2164 of 2019 in Belazio Construction Private Limited vs. Income-tax Officer, Ward-12(1) (3), where this Court has not interfered with the....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the Petitioner on law regarding jurisdiction is commented on then it is stated that earlier no documents could be examined because it is the case of intimation under Section 143(1) of the Act, then the Assessing Officer reproduced the paragraphs regarding what is meant by "reasons to believe" and passed the order. In view of the fact that there is absolutely no application of mind whatsoever while....