2024 (6) TMI 1298

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....mamoorthy For the Petitioner : Mr. G. Ashokapathy for Pass Associates For the Respondents : Mr. D. Prabhu Mukunth Arunkumar Junior Standing Counsel ORDER An assessment order for assessment year 2015-16 is challenged in this writ petition on the ground of breach of principles of natural justice. 2. By issuing an order dated 01.04.2022 under Section 148A(b) of the Income-tax Act, 1961....

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....here was one transaction and provided documents in relation thereto in response to the notices received over a period of time. With specific reference to the reply dated 14.03.2024 to the show cause notice cum draft assessment order, learned counsel pointed out that all relevant information, including information relating to the income-tax returns of the petitioner's parents, was attached ther....

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....readable form. 6. The petitioner has placed on record the reply dated 14.03.2024 to show cause notice cum draft assessment order dated 12.03.2024. The list of attachments thereto include the I.T. acknowledgment of the petitioner's mother and father, documents pertaining to sources of income and bank statements. The petitioner had previously enclosed all documents pertaining to the purchase ....

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.... consideration, as not extractable." 7. In effect, on the basis that the petitioner's reply and documents attached thereto could not be extracted and examined, the order was issued. In the factual context of the petitioner having submitted a reply along with relevant documents, the non-consideration thereof violates principles of natural justice. Hence, the impugned assessment order is unsu....