2021 (11) TMI 539

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.... said Act annexed to the petition is not legible, Mr. Agrawal tenders a fresh print out of the same, which is taken on record and marked "X" for identification. Petitioner to annex this document alongwith the document annexed to the petition during the course of today. Re-verification dispensed with. 2. According to petitioner, the notice issued is bad in law and invalid because the requirements under Section 147 of the Income Tax Act, 1961 (the said Act), have not been satisfied before issuing the impugned notice. According to petitioner, the reasons, which were given alongwith the impugned notice clearly pertains to some other assessee and not petitioner. Mr. Agrawal submitted that subsequently also two further reasons have been given to....

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....espond to their notices and in some cases, the assessee is directed to, within two or three days file documents running into thousand of pages or many third party documents which has to be collected from third parties. Such unreasonable notices have been issued even during lock down period, assessment orders are passed rejecting the request for adjournment without considering the submissions made or documents filed and without even granting personal hearing. Since we did not grant further time, Mr. Chhotaray agreed to argue on the basis of documents filed with the petition. 4. We have heard the counsels and perused the petition and the documents annexed thereto. Petitioner has been served an approval dated 30th March 2019 issued under Sect....