2024 (9) TMI 538

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.... J. (ORAL) For the Petitioner: Mr. Harish Bindumadhavan, Ms Priyanka Rathi, Mr. Ashwini Chandrasekaran & Ms. Shubhangi Gupta, Advocates. For the Respondents: Mr. Rajeev Aggarwal, ASC JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 30.04.2024 whereby the impugned Show Cause Notice dated 19.12.2024 proposing a demand of Rs. 10,04,94,110.00/- against the petition....

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....r before Respondent on April 15,2024 for the adjudication of summary notice. 5. Pursuant to the direction, Petitioner filed detailed reply dated 18.04.2024 and an additional reply dated 24.04.2024, however, the impugned order dated 30.04.2024 does not take into consideration the reply submitted by the Petitioner and is a cryptic order. 6. Perusal of the Show Cause Notice dated 19.01.2024 sho....

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....axpayer is not satisfactory. It states that "And whereas the taxpayer has filed the reply in DRC-06, along with detailed reply and supportive documents. The same has been examined in light of the clarification submitted along with attachment/annexure. The taxpayer has filed the reply is not satisfactory and the relevant/supporting documents not furnished by the taxpayer. Hence, the demand is still....

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....eply dated 18.04.2024 and 24.04.2024 filed by the Petitioner are detailed replies with supporting documents. Proper Officer had to at least consider the reply on merits and then form an opinion. He merely held that the reply is not satisfactory and relevant/supporting documents not furnished which ex-facie shows that Proper Officer has not applied his mind to the reply submitted by the petitioner.....