2021 (3) TMI 332

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ed by the Revenue, disposing of the petitioner-assessee's objection to the notice. 2. It is not in dispute that the notice dated 27.03.2018 was issued by the Revenue on account of the purported failure on the part of the petitioner-assessee to file income tax return qua Assessment Year (AY) 2011-2012. 2.1. Since the petitioner-assessee sought reasons for reopening the case, under Section 147 of the Act vide communication dated 02.04.2018, the reasons were furnished by the Revenue vide communication dated 09.04.2018. 3. Apart from anything else, Mr. Rajesh Mahna, who appears on behalf of the petitioner-assessee, has made two significant submissions. 3.1 First, that the notice under Section 148 of the Act, which, as indicated abov....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....his case had been flagged by the Non-Filers Monitoring System (NMS), put in place by the Income Tax Department. 4.2. Ms. Mujahid says that the aforementioned communication (which was a computer-generated letter) was, consequently, attempted to be served on the petitioner-assessee which, though was returned by the postal department and, thus, left with no option, service was effected on the authorized representative of the petitioner-assessee. 4.3. Ms. Mujahid submits that since no response was received to its communication and the petitioner-assessee's ITR could not be found in the system, the Revenue took the next step, which was, the issuance of notice under Section 148 of the Act. 4.4. Ms. Mujahid, however, cannot but accept tha....