asmt-10 issue raised in show cause notice

[AK ASSOCIATES]

hello,

the department has raised an issue about 2017-18 through ASMT-10 and reply was filed in ASMT-11 and it was closed through ASMT-12. But, the same issue has been raised in SCN and orders were passed without considering the extension of time request before 31.12.2017. Now, whether rectification of the order is possible or appeal on the PNJ ground? kindly advised, thanks.

AI Summary

Violation of natural justice supports appeal where extension request was ignored in assessment proceedings rather than rectification.
Advisers recommend appealing an assessment order where a previously closed ASMT-12 matter was reopened by a show cause notice and the authority passed an order without considering an extension of time request. Key preparatory steps are to establish dates of the SCN and order, how and when the extension was filed, any denial communication, and whether the ASMT-12 closure was presented; the preferred ground is violation of the principle of natural justice rather than seeking rectification.