2022 (12) TMI 1171

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....aptioned writ petition (hereinafter 'impugned order' for the sake of brevity, convenience and clarity). To be noted, impugned order has been made by the sole respondent under Section 144 of IT Act by resorting to Best judgment assessment. 2. The writ petitioner has deposited huge sums of money after demonetisation regime kicked in. Such deposits in the bank account of the writ petitioner have been treated as unexplained income under Section 69A of IT Act in the impugned order. 3. Notwithstanding very many averments in the writ affidavit, learned counsel predicates her submission on one pivotal point and that is the writ petitioner had in fact responded to the Section 142 (1) notice dated 30.11.2017 by way of return on 15.04.20....

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....after the PAN got migrated from Circle-2, Tirupur to Ward - 2(4), Tirupur. The Respondent was not aware of the responses filed by the petitioner,as the same was not reflected in the ITBA (Income-tax Business Application) portal. This was merely a technical problem in the system which cropped up on migration of the PAN. I submit that this technical problem could not be highlighted during the course of assessment proceedings or before passing the assessment order, as the Respondent was not aware that the petitioner had already uploaded the details. As the case was getting barred by limitation of time, the assessment order was finally passed on 16.12.2019, after confirming that the petitioner has not responded to any of the notices/letters iss....