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document.write('<li class="rss-item"><a class="rss-item" href="https://itatonline.org/digest/tumkur-minerals-pvt-ltd-v-jcit-2023-330-ctr-177-291-taxman-340-bom-hc/" target="_self">Tumkur Minerals Pvt. Ltd. v .JCIT (2023) 330 CTR 177/ 291 Taxman 340 (Bom)( HC)</a><br />');
document.write('The Assessing officer  in the reasons recorded has not mentioned what material facts were not disclosed by the assessee during the course of assessment proceedings and has simply recorded the amount of income which has escaped tax and the department has by affidavit sought to state what material facts were not disclosed which is impermissible. Even if the reasons are taken holistically, what material facts are not disclosed is not pointed out and therefore the notice is liable to be quashed. ( AY. 2012 -13');
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document.write('<li class="rss-item"><a class="rss-item" href="https://itatonline.org/digest/vijay-ramanlal-sanghvi-v-acit-2023-330-ctr-424-146-taxmann-com-55-guj-hc/" target="_self">Vijay Ramanlal Sanghvi v. ACIT (2023) 330 CTR 424/ 146 taxmann.com 55 (Guj.)( HC)</a><br />');
document.write('Where it is was the case of the Assessing Officer  that the assessee was a beneficiary of accommodation entries to the tune of Rs. 2.1 crore, but however the assessee supplied all documents and information to the AO during the course of assessment proceedings such as bank statement and bank interest, then the AO cannot conduct a roving inquiry when the amount received was admittedly returned. Notice was  quashed.(AY. 2011-2012');
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document.write('<li class="rss-item"><a class="rss-item" href="https://itatonline.org/digest/viswabharathi-medicals-v-ito-2023-330-ctr-445-221-dtr-309-ker-hc/" target="_self">Viswabharathi Medicals v. ITO (2023) 330 CTR 445 / 221 DTR 309 (Ker)( HC )</a><br />');
document.write('Where the order was passed disposing off the petitioner’s objections, simply because the reply of the petitioner was not adequately considered cannot occasion a failure of natural justice. The judgments relied by the Petitioner in Divya Capital and Rithala Education deal with different situations and are not relevant. Notice and speaking order upheld. (AY.2016-2017)');
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document.write('<li class="rss-item"><a class="rss-item" href="https://itatonline.org/digest/u-s-associates-v-pcit-2023-330-ctr-317chattisgarh-hc/" target="_self">U.S Associates v. PCIT (2023) 330 CTR 317(Chattisgarh)( HC)</a><br />');
document.write('Where the assessee has received a notice under Section 148A(b) with certain information then the Assessing officer cannot travel beyond the show cause notice and pass an order under Section 148A(d) on other grounds. Followed  Commissioner of Customs v. Toyo Engineering India  Ltd  ( SC) ( WP ( T ) No. 254 of 2022 dt .1-12 -2022 ) ');
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document.write('<li class="rss-item"><a class="rss-item" href="https://itatonline.org/digest/savithri-naidu-v-acit-2023-330-ctr-200-212-dtr-462-mad-hc/" target="_self">Savithri Naidu v. ACIT (2023) 330 CTR 200 / 212 DTR 462 (Mad)( HC)</a><br />');
document.write('The  time frame  for framing an assessment in terms of section 153C  has been fixed bearing in mind the practical consideration that assimilation of materials  relating to third person to whom those assessment relates, is bound to take some time . More often than not , it is only upon competition of  the primary assessment ( Under section 153A))  that the  Assessing Officer  eve comes to a reasoned conclusion as to whether proceedings are to be initiated against such a person or not .   Seized material was handed over on 27 -8 2019 hence the order is not barred by limitation Writ petition was dismissed- Directed to pursue alternative remedy   (AY.2015-2016)');
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