TaxTMI 
TaxTMI 
2024 (8) TMI 756
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....nsel for the respondents. 2. In these Writ Petitions, the petitioner has challenged the impugned Assessment Orders dated 15.02.2024 and 25.02.2024 for the Assessment Years 2019-2020 and 2018-2019 respectively. Pursuant to the aforesaid impugned orders, the tax liability of the petitioner comes to Rs. 11,62,97,403/- for Assessment Year 2018-2019 and Rs. 14,22,82,995/- for Assessment Year 2019-2020. 3. It is the case of the petitioner that M/s.Sri Ramajayam Agencies, the petitioner herein, was originally constituted as a partnership firm consisting of the deponent's father Thirusangu, the deponent T.Pandiyaramanaryanan and the deponent's brother T.Venkatesan. It is further case of the petitioner that the said partnership firm was as....
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....its in its name. These are the amounts which are paid back to the Petroleum Company and the deponent is having thin margin and tax is assessed in the individual name. 7. It is submitted that the impugned orders determining the above-mentioned tax are unjustified and unwarranted and that one opportunity may be given to the petitioner to explain the case as the mistake has arisen only on account of the fact that the petitioner has not surrendered the PAN after the deponent took over the business in the individual capacity. 8. On the other hand, the learned Senior Standing Counsel for the respondents would submit that the notices were not only sent through the Email but also to the postal address where the deponent carries on business and fi....
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...., 1961, for the partnership firm, as it has purportedly closed down its business w.e.f. 01.04.2014. 12. The petitioner will have to establish whether the huge deposits made in the petitioner's bank account have been brought into the books of accounts under the name of the deponent. This would require a detailed consideration. 13. However, considering the fact that the deponent has been negligent in not responding to the notices issued under Section 148A(b) of the Income Tax Act, 1961 and thereafter to the orders passed under Section 148A(d) of the Income Tax Act, 1961, I am inclined to quash the impugned Assessment Orders and remit the case back to the first respondent to pass fresh orders subject to the certain terms:- i. Consideri....