2024 (5) TMI 655

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....N.C. Kaushik, Additional Government Pleader (T) An assessment order dated 22.12.2023 is assailed primarily on the ground of non application of mind. 2. The petitioner is a manufacturer of drip irrigation sprinkler systems and has its head office at Pitampur, near Indore. Consequently, the petitioner has places of business outside Tamil Nadu. Pursuant to audit proceedings, the petitioner received....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the tax payer did not file any objection/reply or avail of the opportunity of personal hearing. Since the impugned assessment order is completely unreasoned, learned counsel contends that such order is not sustainable. 4. Mr. T.N.C. Kaushik, learned Additional Government Pleader, accepts notice for the respondents. He submits that a show cause notice was issued and the petitioner's reply was ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....'s certificate dated 12.10.2023 and the petitioner's reply dated 13.10.2023, the above findings are completely unsustainable and clearly indicate non application of mind. Even otherwise, the impugned order appears to be completely unreasoned. Hence, interference is warranted with the order. 6. For reasons set out above, the impugned assessment order dated 22.12.2023 is quashed and the mat....