Best judgment assessment upheld where return was overdue, notices went unanswered, and search did not excuse non-filing.

The return was due before the search and seizure, and the taxpayer did not seek extension, respond effectively to notices, or avail the opportunity to copy seized documents. On that factual basis, the explanation that search and non-supply of documents prevented filing was found insufficient, so the cancellation of registration and best judgment assessment were not interfered with and the challenge failed.

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Issues: Whether the petitioner was entitled to interference with the orders cancelling registration and making best judgment assessment on the ground that it could not file its return because of search and seizure and non-supply of seized documents.

Analysis: The return for the relevant assessment year was due before the search and seizure. The petitioner did not seek extension of time under section 139(2) of the Income-tax Act, 1961, did not effectively respond to the notices issued under sections 139(2) and 142(1) of the Act, and did not avail the opportunity offered to take copies of the documents. The explanation based on search and seizure was therefore found insufficient to justify the failure to file the return or to displace the assessment action taken by the Department.

Conclusion: The challenge to the impugned orders was rejected and no interference was warranted.

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