The impugned order was invalid due to non-application of mind and failure to consider the assessee’s detailed reply; the matter was remanded for fresh consideration { Mark Studio India Private Limited vs Income Tax officer {[2024] 2025 (6) TMI 595166 taxmann.com 147 (Madras)}
Facts of the Case:
- The assessee, Mark Studio India Pvt. Ltd., received a show cause notice from the Income Tax Department.
- In response, the assessee filed a detailed reply, addressing each issue raised in the SCN and submitting supporting documents.
- Despite this, the Assessing Officer passed an impugned order that repeated the same observations for each issue, stating that the assessee had not submitted proper documents.
- The order did not reflect any consideration of the assessee’s reply or documents.
Issue:
- Whether the impugned order passed by the Assessing Officer was valid when it failed to consider the assessee’s reply and documents.
Held:
- The Madras High Court held that the impugned order was vitiated due to complete non-application of mind.
- The officer failed to consider the assessee’s reply and documents, which amounted to a violation of principles of natural justice.
- Consequently, the Court set aside the impugned order and remanded the matter back to the authority for fresh consideration in accordance with law.
