Document Fragment View

Matching Fragments

(iii) the notice of assessment was issued under the dictates of the Audit party and there has been no independent application of mind by the S.T.O. nor any reason has been recorded to show any application of mind.
(iv) it was also urged that since the petitioner became entitled to refund of a sum of Rs. 66,775/- as a result of the assessment order for the year 1 994-95 and since the petitioner made an application for refund, the S.T.O. set in motion a proceeding for re-opening the assessment.