2021 (10) TMI 750

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....r Sharma for respondents - Revenue.   P.C. : 1. Since pleadings are completed, we decided to dispose this petition at the admission stage itself by consent of the parties. Rule. Rule made returnable forthwith. 2. Petitioner is impugning the assessment order dated 8th June 2021 read with the notice of demand dated 8th June 2021 issued under Section 156 read with show....

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.... its response by 23:59 hours of 24th April 2021 (4th Saturday). Petitioner was also advised that they may request for personal hearing. 4. On 23rd April 2021 petitioner filed its response mentioning therein, inter alia, that due to increase in COVID-19 cases, traveling was a problem, staff were not able to attend and offices in Mumbai are generally closed. Respondents were informed that petitio....

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....elf shows that respondents have passed the assessment order without application of mind, without considering the two replies dated 23rd April 2021 and 27th April 2021 filed by petitioner and without considering the request for personal hearing also sought by petitioner. Strangely in the affidavit in reply filed by one Yashpal Singh affirmed on 29th July 2021, it is stated that "the noting records ....

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....sion dated 27th April 2021 has been taken on record and considered. 7. We have perused with the assistance of Mr. Jain the statement dated 27th April 2021 which gives the quantitative details. Mr. Sharma tried to justify the stand of respondents by stating that the quantitative details filed on 27th April 2021 are not strictly according to the format prescribed. We have compared the details pro....