2023 (12) TMI 350

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....hesh Sinha, Adv. For the Respondents Through: Ms Priya Sarkar, Standing Counsel for Mr Shlok Chandra, Sr Standing Counsel. RAJIV SHAKDHER, J.: (ORAL) 1. We had heard the matter at some length on 03.05.2023 and briefly etched out the broad contours of the case. For convenience, the relevant parts of the order dated 03.05.2023 are set forth hereafter: "2. This writ petition concern....

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.... 5.1 It is Mr Sinha's contention, that the copies of GSTR 2A/2B were also furnished, along with the bank statement of the subject bank account, wherein payments have been received via RTGS. 5.2 Mr Sinha has drawn our attention to the CBDT guidelines and instruction dated 22.08.2022 respectively. In support of his plea, that the procedure prescribed therein had not been followed by the ....

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....search actions taken out against the aforementioned entities. 8. We may note, that one of the grievances articulated by Mr Sinha is, that even though oral hearing was sought by the petitioner, the same was not granted. 8.1 It is Mr Sinha's contention, that if a hearing was granted, perhaps some of the doubts which the AO raised would have got clarified. 9. A perusal of b....

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.... order." 2. As would be evident from the above extract, the following two grievances were articulated by Mr Ruchesh Sinha, learned counsel, who appears on behalf of the petitioner/assessee: (i) First, there was no inquiry conducted before directing the reassessment proceedings; (ii) Second, had the Assessing Officer (AO) granted an oral hearing, his queries could have been add....