TaxTMI 
TaxTMI 
2024 (12) TMI 1268
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....s provided for reopening post issuance of notice under Section 148 of the Income Tax Act 1961 (the Act) were incomplete as ex-facie seen from the reasons annexed to the approval under Section 151 of the Act. The proceedings of the said Writ petition were adjudicated by this court. By an order dated 23rd January 2024 the Court disposed of the petition by quashing and setting aside the order dated 16th February 2022 passed by the Assessing Officer disposing of the objection as raised by the petitioner to the notice under Section 148. What is significant, is the court recording the reasons that were made available to the petitioner vide communication dated 30th April 2021 and the reasons annexed to the approval under Section 151 of the Act wer....
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....r shall deal with every point raised by petitioner. Before passing any order, personal hearing shall be granted notice whereof shall be communicated atleast five working days in advance. The proceeding will be concluded on or before 30th April 2024. 7 After passing an order disposing objections filed by petitioner, in case the objections are not accepted by the Assessing Officer, then the Assessing Officer should complete reassessment proceedings on or before 30th June 2024 as per the provisions of law. 8 Petition disposed. 9 We clarify that we have not made any observation on the merits of the matter." 3. On the aforesaid backdrop the proceedings were remanded to the Assessing Officer. Subsequent thereto there was also correspon....
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.... the respondents were required to undertake in accordance with law, as directed by this Court and more particularly in respect of the objections which were raised in paragraph 7 and to which we have made reference hereinabove. 5. We have perused the impugned order. Although Mr. Walve has raised several contentions to point out very serious defects in the impugned order disposing of the petitioner's objections, we do not intend to delve on all contention, suffice it to observe that we are more than satisfied that the fresh objections as raised by the Petitioner have not been dealt / disposed of despite a specific order to that effect passed by this court, much less in the manner according to law. In fact the impugned order in our opinion sh....