2025 (3) TMI 1948

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n law the Assessing Officer erred in reopening u/s 148 and passing order u/s 147 r.w.s 144 a. Mechanically b. Without making any inquiry c. Only on the basis of borrowed information d. even though the reopening was required to be done by FAO instead of JAO e. without serving notice u/s 148A(b) at proper address f. without providing reasons for reopening g. without granting opportunity of being heard personally h. without serving order u/s 148A[d] i. No asset is found above RS 50 lac j. Notice issued after 3 years k. Obtaining prior approval of Pr. Commissioner of Income Tax-20 instead of Pr. Chief Commissioner of Income Tax. 1. Consid....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....dated 02/05/2023 physically on 12/04/2024 through income tax officer ward 22(1)(1) because the same was not reflected on income tax portal till 11/04/2024. 7. I humbly pray before your honor to condone the delay of 319 days of filing appeal from 01/06/2023 to 15/04/2024 and the same is a very bona fide reason on account of which the delay has occurred. The Appellant has not been negligent and wants to pursue the Appeal remedy, in as much as, on merits. 4. After having heard the counsels for both the parties and considering the documents placed on record and also taking into consideration the contents of the affidavit and considering the principles laid down by Hon'ble Supreme Court of India in the case of Land Acquisition Collec....