Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Validity of electronically issued assessment orders was contested for absence of a DIN and unsigned show cause notices; the HC recorded that the assessment carried a portal-generated Reference No (auto-assigned and exclusive to that assessment) and rejected the challenge to electronic issuance on that basis. The HC also found the petitioner aware of assessment action and unable to explain delay between appeal rejection and writ filing; on the ground of laches the writ petition was dismissed. No substantive grounds raised in the petition were sustained.
Validity of electronically issued assessment orders was contested for absence of a DIN and unsigned show cause notices; the HC recorded that the assessment carried a portal-generated Reference No (auto-assigned and exclusive to that assessment) and rejected the challenge to electronic issuance on that basis. The HC also found the petitioner aware of assessment action and unable to explain delay between appeal rejection and writ filing; on the ground of laches the writ petition was dismissed. No substantive grounds raised in the petition were sustained.
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