Section 148A(d) order upheld where response time was granted and later reply did not show timely non-consideration.

An order under Section 148A(d) of the Income-tax Act was not interfered with where the record showed that time to respond had been granted up to 14.04.2023 and the impugned order was passed on 21.04.2023. The later reliance on a reply said to have been filed after the order did not establish that a timely response or extension request had been ignored. The cited precedent was distinguished on facts, and the matter was also noted to be at a non-final stage because notice under Section 148 had already been issued, leaving the assessee free to raise all contentions in response.

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Issues: Whether the order passed under Section 148A(d) of the Income-tax Act, 1961 was liable to be interfered with on the ground that the assessee's reply and request for further time were not considered or communicated.

Analysis: The petitioner's grievance was that the reply was not considered and that the extension of time granted for filing a response was not communicated. The record showed that time had been granted up to 14.04.2023 and the impugned order was passed on 21.04.2023. The later reliance on a reply stated to have been filed after the order did not establish that the authority had ignored a timely response. The decision cited by the petitioner was distinguished on facts, and the Court also noted that the impugned order under Section 148A(d) was not the final stage because notice under Section 148 had already been issued, leaving the petitioner free to urge all contentions in response.

Conclusion: The impugned order was not interfered with, and the writ petition was dismissed.

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