2023 (6) TMI 1410

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Gandhi For the Respondents : Mr. Ajeet Manwani a/w Ms. Samiksha Kanani ORDER WRIT PETITION NO. 6410 OF 2022 1. The petitioner is aggrieved by notice dated 31/03/2021 issued under Section 148 of the Income Tax Act, 1961 ('the Act') and the order dated 22/02/2022 rejecting petitioner's objections. 2. Though various grounds have been raised, two grounds that Mr. Gandhi highlighted at the outset ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s been stated "From the perusal of ITR, it is not established that the gross receipts of the assessee are in Cash", but this allegation has not been raised in the reasons recorded for reopening. Mr. Gandhi also submitted that in the same paragraph 4 of the impugned order, it is stated "Hence, the source of cash deposits amounting to Rs. 85,94,597/- and Rs. 6,00,000/- against insurance premium to H....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 6. Therefore, on this ground alone, the impugned order dated 22/02/2022 is required to be quashed and set aside, which we hereby do. 7. At the same time, without making any observations on merits of the matter and keeping open all rights and contentions of petitioner, the matter be remanded to the Jurisdictional Assessing Officer (JAO) who shall dispose petitioner's objections within 4 weeks of ....