order. He contended that the impugned order exhibits complete non application of mind and that said order is unreasoned. By way of illustration, learned counsel referred to the second head dealt with therein relating to 'turnover mismatch'. He submitted that the assessing officer referred to the petitioner's reply and thereafter merely recorded that the reply of the dealer is not acceptable. Likewise, in respect of the fifth head dealing with 'reversal of Input Tax Credit (ITC)', he submitted that the petitioner's reply is set out in the impugned order, wherein the petitioner stated that ITC was availed and used only for taxable and zero-rated supplies, whereas the assessing officer recorded that ITC is liable to be reversed because the petitioner had used it partly for exempt supplies. By also referring to the seventh head relating to 'sundry creditors', learned counsel pointed out that the assessing officer recorded that relevant documents like invoices, bank statements and ledger copies were not produced. By turning to the reply dated 09.10.2023, he pointed out that the bank statement was given as a soft copy, as is evident from the list of enclosures to the reply.
