2021 (5) TMI 639

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.... show cause notice at Ext.P4 dated 18.03.2021 whereby he was informed by the Assessing Officer to submit his response through registered e-filing account by 23.59 hours of 22.03.2021. It is argued that this show cause notice was accompanied by the draft assessment order and is came to be issued as per provisions of Section 144C of the Income Tax Act, 1961. 3. Learned counsel appearing for the pet....

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.... it is mentioned that the assessee was required to respond by 22.03.2021 but he did not respond to the same till the time of passing of the order at Ext.P7. Ext.P7 assessment order is dated 23.03.2021 and it is seen that the reply to the show cause notice at Ext.P4 notice was tendered by the petitioner on 23.03.2021 at Ext.P6. Learned counsel appearing for the petitioner therefore argued that the ....

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....mediately responded by the communication at Ext.P5 and sought time only upto 27.03.2021 to file reply to the show cause notice and he did reply to the show cause notice by his reply (Ext.P6) dated 23.03.2021. However, that reply is not considered while passing the assessment order at Ext.P7 rather it is noted therein that petitioner did not respond to the show cause notice at Ext.P4. 7. At this s....