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K. SOMASHEKAR, RAJESH RAI K.
DEPUTY COMMISSIONER OF INCOME TAX, BENGALURU – Appellant
Versus
SUNIL KUMAR SHARMA S/O SHRI D. P. SHARMA – Respondent
| Table of Content |
|---|
| 1. introduction of facts and context regarding income tax search and assessment procedures. (Para 1 , 4 , 6 , 33) |
| 2. court's observations on evidentiary standards and procedural adherence in tax assessments. (Para 7 , 10 , 14 , 16) |
| 3. arguments surrounding the validity of assessments based on loose sheets and the processes followed. (Para 8 , 11 , 18 , 20) |
| 4. ratio decidendi regarding procedural propriety in tax assessment notices. (Para 12 , 25 , 40) |
JUDGMENT :
K. SOMASHEKAR, J.
1. These appeals have been preferred by the Deputy Commissioner of Income Tax, Circle 1(4) (for short ‘Revenue’), challenging the common order dated 12.08.2022 passed by a learned Single Judge of this Court in W.P. No. 9937/2022 and connected matters. All these appeals are directed against one Shri Sunil Kumar Sharma who is the respondent in W.A. Nos. 830/2022, 831/2022, 832/2022 and 833/2022 and one Shri Kandaswamy Rajendran who is the respondent in W.A. No. 834/2022. The respondents shall hereinafter be referred to as ‘the assessee’ for brevity.
2. Since all these appeals which have been preferred by the Revenue arise out of a common order dated 12.08.2022 rendered by a learned Single Judge in W
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