2023 (6) TMI 1353

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....nd Mr. Anirban Chatterjee, Adv. For the Respondents : Mr. Prithu Dudhoria, Adv. ORDER Heard learned advocates appearing for the parties. By this writ petition, petitioner has challenged the impugned order dated 13th April, 2023 under Section 148A(d) of the Income Tax Act, 1961 relating to assessment year 2019-20. I have perused the aforesaid impugned order from which it appears that there is ....

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....assessing officer has considered the said reply. It may be that the assessing officer has come to a different conclusion but that does not mean that the assessing officer has not given the petitioner any opportunity of hearing or the assessing officer will have to agree with the contention of the petitioner. Findings against the petitioner based on material evidence cannot be re-appreciated and sc....