Case Law Details
Nanjappan Senthilkumar Vs Deputy Commercial Tax Officer (Madras High Court)
In the case of Nanjappan Senthilkumar vs. Deputy Commercial Tax Officer, the petitioner challenged an order dated October 10, 2023, issued in response to discrepancies found in their tax returns. The matter originated from a notice dated June 22, 2023, which alerted the petitioner to inconsistencies in their filings. The petitioner promptly responded to this notice on April 11, 2023. Subsequently, a show cause notice was issued, initiating formal proceedings that culminated in the disputed order.
The crux of the petitioner’s argument, presented by their counsel, was the lack of reasoning in the impugned order. Specifically, they highlighted a stark disparity: while the initial tax demand specified in the show cause notice amounted to Rs. 5,570, the final tax liability determined in the impugned order ballooned to Rs. 1,07,410. This substantial increase was not accompanied by any explanation or justification within the order itself.
In response, Mr. C. Harsha Raj, representing the government as the learned Additional Government Pleader, acknowledged receipt of the notice on behalf of the respondent authority. However, he did not dispute the petitioner’s contention regarding the lack of reasoning or the disproportionate increase in tax demand.
Upon examining the impugned order, the Madras High Court noted the absence of any substantive reasons provided therein to support the significant escalation in tax liability beyond what was initially notified in the show cause notice. This omission, coupled with the stark difference in the amounts, led the Court to conclude that the order lacked the necessary rationale and justification required under legal principles.
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