Court dismisses writ petition challenging Income Tax Act order, emphasizes procedural compliance and substantiated claims.

The Court dismissed the writ petition challenging the impugned order under Section 148A (d) of the Income Tax Act, 1961 for the assessment year 2018-19. The Court found no procedural irregularity in the Assessing Officer's actions and emphasized the petitioner's opportunity to present their case following the notice under Section 148 of the Act. The judgment highlighted the importance of complying with procedural requirements and providing substantiated claims in legal proceedings.

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Issues:
Challenge to impugned order under Section 148A (d) of the Income Tax Act, 1961 for assessment year 2018-19 based on lack of consideration of petitioner's objection and failure to respond to the notice dated 11th March, 2022 issued under Section 148A (b).

Analysis:
The petitioner contested the impugned order dated 23rd March, 2022, arguing that it was passed without due consideration of the petitioner's objection and non-response to the notice issued under Section 148A (b) of the Act. The petitioner failed to provide evidence of responding to the notice by the stipulated deadline of 18th March, 2022, or seeking an extension for submission. Despite the petitioner's claim that their Chartered Accountant orally requested more time, this assertion lacked supporting evidence in the writ petition. The Court clarified that it cannot verify oral statements without proper documentation, emphasizing the need for substantiated claims in legal proceedings.

The Court, in its assessment, found no procedural irregularity on the part of the Assessing Officer in issuing the impugned order. The judgment highlighted that the petitioner still had the opportunity to present their case following the notice under Section 148 of the Act, indicating that avenues for challenging the reassessment remained open. Consequently, the Court declined to intervene in the matter, leading to the dismissal of the writ petition (WPO No. 1943 of 2022). The decision underscored the importance of complying with procedural requirements and providing substantiated claims in legal proceedings to ensure a fair and transparent adjudication process.

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