2024 (4) TMI 160

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....DEJA Advocates who appeared in this case: For the Petitioner: Mr. P. K. Gambhir, Mr. Rakesh Kumar, Mr. Deepak Kumar Shrivastva, Mr. Dalip Kumar Shrivastva, Mr. Sumit Shrivastva & Mr. Yogesh Kumar, Advocates. For the Respondents: Mr. Rajeev Aggarwal, ASC for R-1 & 3. JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 28.12.2023, whereby the impugned Show Cause Notice ....

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.... said Show Cause Notice, a detailed 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 "Now, since reply/explanation submitted by the taxpayer is not satisfactory. In view of aforesaid circumstances, the under....

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.... the same could have been specifically sought from the Petitioner. However, the record does not reflect that any such opportunity was given to the Petitioner to clarify its reply or furnish further documents/details. 7. In view of the above, the order cannot be sustained, and the matter is liable to be remitted to the Proper Officer for re-adjudication. Accordingly, the impugned order dated 28.12....