2023 (6) TMI 1286

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....9;BLE SHRI JUSTICE ROHIT ARYA AND HON'BLE SHRI JUSTICE SATYENDRA KUMAR SINGH FOR THE PETITIONER : SHRI SUNIL KUMAR JAIN - ADVOCATE FOR THE RESPONDENTS : SHRI HARSHWARDHAN TOPRE -ADVOCATE ORDER This petition coming on for admission this day, JUSTICE ROHIT ARYA passed the following: ORDER Petitioner, an assessee with Permanent Account Number (PAN) AAOHP9851J allotted to him in the year....

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....cer has passed the order overruling the objection raised against initiation of re-assessment proceedings. Learned counsel for the petitioner while taking exception to the impugned notice and order inter alia submits that subsequent to allotment of new PAN Card in the year 2016 it has all along been filing returns of the income for the succeeding assessment years including 2016-17 with new PAN Car....

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....y be. That apart, petitioner HUF is shown to be at Delhi, however the account of the petitioner is in Shivpuri. Besides, the petitioner HUF is said to be in the name of Padam Chand Jain HUF whereas account is maintained in the name of Ballabh Chand. Under such circumstances, no exception can be taken to the formation of the opinion for re-assessment proceedings as unless the amount found deposited....

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....assessment proceedings. The Assessing Officer is statutorily obliged to look into the entire material placed before him before he reaches the conclusion that the income found has escaped assessment warranting re-assessment and tax thereupon. Consequently, we though decline to interfere but direct the Assessing Officer to extend liberty to the petitioner to file complete documents with reference t....