Section 73 notice upheld, with liberty to file a fresh reply and obtain reconsideration after hearing.

A notice issued under section 73 was not quashed despite the petitioner's objection that its earlier reply had not been considered and that the appended table appeared to relate to a different assessee. The Court noted that proceedings had begun under section 61, the reply was found unsatisfactory, and further time was granted for a fresh response. In the interest of justice, the petitioner was allowed to file a detailed reply confined to its own returns, and the respondent was directed to consider that reply afresh after granting a personal hearing.

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Issues: Whether the notice under section 73 required interference in view of the petitioner's objection that the earlier reply had not been considered and that the table appended to the notice related to a different assessee.

Analysis: The dispute centered on the alleged non-consideration of the petitioner's earlier reply and the apparent mismatch between the petitioner's case and the particulars reproduced in the notice, which referred to another concern. The respondent stated that proceedings had commenced under section 61 and that, after the reply was found unsatisfactory, notice under section 73 was issued, with further time granted to reply. The Court found that the petitioner's grievance was essentially that its own reply and objections had not been properly examined. In the interest of justice, the petitioner was to be allowed to submit a detailed reply confined to its own returns, and the respondent was to consider the same after granting personal hearing.

Conclusion: The notice was not quashed; the petitioner was directed to file a fresh detailed reply and the respondent was directed to decide the matter afresh after hearing the petitioner.

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