2024 (2) TMI 754

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.... the Respondents-Revenue : Mr. Akhileshwar Sharma. PC : 1. Petitioner is seeking quashing of the final assessment order issued under Section 143(3) read with Sections 144B and 144C of the Income Tax Act, 1961 ("the Act"), the notice of demand issued under Section 156 of the Act, the penalty notice issued under Section 270A of the Act and another penalty notice issued under Section 271AAC of ....

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....ner of Income Tax, Circle-15(3)(2) and others that once the objections were uploaded, admittedly in the ITBA Portal, the same would have been accessible even to the AO. Petitioner was on a reasonable belief that once having intimated its objections vide a communication dated 4th December 2023, copy of objections filed separately with the acknowledgment need not be given to the AO, though the asses....

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....impugned in this petition. We would also observe that the AO cannot be faulted for passing the impugned order. At the same time, the AO will also have benefit of considering the views of DRP while passing a fresh assessment order. 7. Accordingly, petition is allowed in terms of prayer clause (a), which reads as under : "a. that this Hon'ble Court be pleased to issue a Writ of Certiorar....