Court grants relief to petitioner, quashing hasty tax assessment orders amid COVID-19, allowing time extension.

The court allowed the petitioner's writ petitions seeking to quash orders by the Income Tax Officer for Assessment Years 2012-13 and 2013-14 under the Income Tax Act. The court noted the undue haste in passing orders during the COVID-19 lockdown, contradictory observations in the impugned order, and the petitioner's requests for time extensions. The Income Tax Department withdrew the impugned orders, granting the petitioner a two-week extension post-lockdown to respond to show cause notices. The court disposed of the petitions, ensuring a fair opportunity for the petitioner to address the issues raised.

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Issues:
1. Petition to quash orders by Income Tax Officer for Assessment Years 2012-13 and 2013-14 under Income Tax Act.
2. Allegation of undue haste in passing impugned orders amidst COVID-19 lockdown.
3. Request for time extension to respond to show cause notices.
4. Contradictory observations in impugned order.
5. Withdrawal of impugned orders by respondent/Department.
6. Granting time extension to petitioner to reply to show cause notices post-lockdown.

Analysis:
1. The petitioner filed two writ petitions seeking to quash orders passed by the Income Tax Officer for Assessment Years 2012-13 and 2013-14 under the Income Tax Act. The petitions also sought to quash demand notices and penalty proceedings initiated by the Income Tax Department.

2. The main grievance raised by the petitioner was the alleged undue haste by the respondent in passing the impugned orders amidst the COVID-19 lockdown. The petitioner had requested an extension of three weeks to respond to show cause notices due to the lockdown situation, but the respondent proceeded with issuing further notices and eventually passing the impugned orders.

3. The petitioner had promptly responded to the initial show cause notices by requesting more time to gather necessary information, citing the lockdown as a hindrance. Despite repeated requests for extension, the respondent did not grant additional time, leading to the passing of the impugned orders.

4. The impugned order itself contained contradictory observations where the Income Tax Officer noted the petitioner's request for an adjournment but later deemed the contentions raised by the petitioner as meritless. This inconsistency in the order raised concerns about the decision-making process.

5. During the proceedings, the respondent, through the Senior Standing Counsel, informed the court about the decision to withdraw the impugned orders for both assessment years and provide the petitioner with an opportunity to reply to the show cause notices issued earlier.

6. The court, considering the circumstances, disposed of both petitions and granted a two-week period post-lockdown withdrawal for the petitioner to respond to the show cause notices. Following the receipt of replies, the respondent was permitted to take further steps in accordance with the law, ensuring a fair opportunity for the petitioner to present their case.

This detailed analysis covers the key issues raised in the judgment, highlighting the sequence of events, legal arguments, and the final resolution provided by the court.

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