2022 (3) TMI 306

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....vocate. Respondents Through: Mr. Pratyaksh Gupta, Advocate. J U D G M E N T MANMOHAN, J (Oral): 1. Present writ petition has been filed challenging the impugned notice dated 28th March, 2021 issued under Section 148 of Income tax Act, 1961 ('the Act') for the assessment year 2015-16. 2. Learned counsel for the Petitioner states that reopening of assessment was done on the sole ground ....

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....in the course of original assessment proceedings under Section 143(3) which is not permissible in law. 4. On the last dates of hearing, learned counsel for the respondents had sought time to obtain instructions. Today, learned counsel for the respondents refers to Note No.24 to the audited accounts and states that the Assessing Officer wished to ascertain as to how the contingent liability on acc....

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....rement of applicable Accounting Standards. 7. The impugned order disposing objections dated 27th December, 2021 also suffers from complete non-application of mind, as there are a lot of repetitions in the impugned order. 8. Consequently, this Court is also of the view that the reason to believe is invalid and has no rational nexus to the belief for escapement of income and there was no fresh mat....