2024 (3) TMI 964

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....ta Jha, Mr. Shammi Kapoor, Ms. Swati Agarwal, Mr. Sandeep Gupta and Ms. Prachi Jain, Advocates. For the Respondents: Mr. Rajeev Aggarwal, Additional Standing Counsel with Ms. Samridh Vats, Advocates. JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 23.12.2023, whereby the impugned Show Cause Notice dated 25.09.2023, proposing a demand against the petitioner has been d....

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....ed reply was furnished by the petitioner giving full disclosures under each of the heads. 4. The impugned order, however, after recording the narration, records that the reply uploaded by the taxpayer is not satisfactory. It merely states that "And whereas, the taxpayer had filed their objections/reply in DRC-06 but he failed to avail the Personal Hearing opportunity on the given due date. On the....

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....plete and not duly supported by adequate documents. He merely held that the reply is not clear and unsatisfactory which ex-facie shows that Proper Officer has not applied his mind to the reply submitted by the petitioner. 6. Further, if the Proper Officer was of the view that the reply is unsatisfactory and if any further details were required, the same could have been specifically sought from th....