2021 (8) TMI 1294

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....r. T. Vasudevan For Respondent : Mr. ANR. Jayaprathap Junior Standing Counsel O R D E R Heard Mr.T.Vasudevan, learned counsel for the petitioner and Mr.ANR.Jayaprathap, learned Junior Standing Counsel who accepts notice for the respondent and is armed with instructions to proceed with the matter finally. 2. The petitioner assails a notice issued under Section 148 of the Income Tax Act,....

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....rein, in both the points cited as being the basis for the impugned re~assessment, reference is made to verification of the records of assessment including Form 3CD of the audit report. Thus, and prima facie, the documents relied upon in support of proceedings for re~assessment are very much part of the records. According to the petitioner, there is no other, let alone tangible material, that has b....

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....urnish reasons within a reasonable time. On receipt of reasons, the noticee is entitled to file objections to issuance of notice and the assessing officer is bound to dispose of the same by passing a speaking order’. 7. Since the impugned proceedings are yet to culminate in a speaking order on the aspect of jurisdiction, I am of the view that this Writ Petition is pre-mature and that the p....