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HC held that the petitioner cannot re-challenge notices issued under ss. 148A(b), 148A(d) and 148, which ought to have been agitated before the DRP; having been directed earlier to raise those issues before the DRP, the petitioner did so but failed to inform the Assessing Officer, whereupon the AO, acting under s.144C, validly passed the final assessment order. In the interests of justice, however, the HC set aside the final assessment order, the demand notice under s.156 read with the issue letter, and the DRP order rejecting objections, and directed revival of the petitioner's objections before the DRP for adjudication on merits. The HC found no fault with the AO's procedural conduct.
HC held that the petitioner cannot re-challenge notices issued under ss. 148A(b), 148A(d) and 148, which ought to have been agitated before the DRP; having been directed earlier to raise those issues before the DRP, the petitioner did so but failed to inform the Assessing Officer, whereupon the AO, acting under s.144C, validly passed the final assessment order. In the interests of justice, however, the HC set aside the final assessment order, the demand notice under s.156 read with the issue letter, and the DRP order rejecting objections, and directed revival of the petitioner's objections before the DRP for adjudication on merits. The HC found no fault with the AO's procedural conduct.
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