2025 (6) TMI 981

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ant : Mr Saurabh Soparkar, Ld.Sr. Adv with Mr Dhinal A Shah (12077) For the Respondent No. 2 : Ms Maithili D Mehta (3206) For the Respondent(s) No. 1 : Notice Served ORAL ORDER (PER : HONOURABLE Mr.  JUSTICE BHARGAV D. KARIA) 1. Heard learned Senior Advocate Mr. Saurabh Soparkar through video conference with learned advocate Mr. Dhinal A. Shah for the petitioner and learned Sen....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....contention of the assessee is that the AO has proceeded to make addition u/s. 69A by stating that the assessee failed to submit certain details mentioned in Point 3 (sub-points 1 to 12) of the order whereas, those details were never called for by the AO. From the records available, this contention of the assessee is also found to be factually correct. 9.2 Thus, from the above facts, it is....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ficer is directed to pass a fresh assessment order. The assessee will be at liberty to adduce the relevant evidence/material before the Assessing Officer at the time of assessment in consequence to this order and the Assessing Officer shall allow the assessee adequate opportunity of being heard and to make relevant submissions." 2.2. In view of the above order, it was submitted that the grievan....