Court upholds assessment orders, dismisses challenges due to lack of response. Orders on rectification applications directed.

The High Court dismissed the Writ Petitions challenging assessment orders for specific years due to the petitioners' failure to respond to notices. The court upheld the procedure followed by the Assessing Authority and deemed the assessment orders justified. Separate Writ Petitions seeking mandamus for rectification applications under Section 154 were disposed of with the court directing the respondents to consider and pass orders on the rectification applications within a specified timeframe.

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Issues:
1. Challenge to three assessment orders for different assessment years under the Income Tax Act, 1961.
2. Mandamus sought for directing the respondents to consider and pass orders on rectification applications under Section 154 of the Act.

Analysis:

Challenge to Assessment Orders:
The petitioners filed Writ Petitions challenging three assessment orders for the assessment years 2015-16, 2016-17, and 2017-18, passed under Section 147 read with Section 144 and Section 144B of the Income Tax Act, 1961. The petitioners were issued notices under Section 148 of the Act on 26.03.2021, followed by a questionnaire under Section 142(1) on 15.11.2021. The petitioners replied stating that the firm mentioned in the notice no longer existed and had been succeeded by a company. Despite subsequent notices, the petitioners failed to respond. The court found no fault in the procedure followed by the Assessing Authority, noting that adequate opportunities were given to the assessees to present their case. The court held that the petitioners' failure to respond to the notices justified the assessment orders, leading to the dismissal of the Writ Petitions.

Mandamus for Rectification Applications:
Separate Writ Petitions were filed seeking mandamus to direct the respondents to consider and pass orders on rectification applications dated 05.05.2022 under Section 154 of the Act. The court directed the respondents to dispose of the rectification applications within sixteen weeks from the date of receipt of the order after hearing the petitioner. Consequently, the Writ Petitions seeking relief for the rectification applications were disposed of in accordance with the court's directive.

In conclusion, the High Court dismissed the Writ Petitions challenging the assessment orders for specified assessment years, citing the petitioners' failure to respond to notices issued by the Assessing Authority. Additionally, the court directed the respondents to dispose of the rectification applications within a specified timeframe, ensuring the timely consideration of the rectification requests under Section 154 of the Income Tax Act, 1961.

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