2021 (5) TMI 1009

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....he impugned assessment order concerns the assessment year 2018-2019. 2. On the previous date, i.e., 26.04.2021, when the matter came up before us, for the first time, we had issued notice to the respondents and the following aspects were recorded. These aspects, in essence, captured the core grievance of the petitioner: "2. Mr. Gautam Jain, who appears on behalf of the petitioner-assessee, says that a notice dated 02.04.2021 has been served on the petitioner concerning the assessment year (in short "AY") 2018-2019 to show cause as to why the assessment should not be completed in consonance with the draft assessment order. 2.1 Mr. Jain goes on to state that the response to the said show cause notice had to be served on t....

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....04.2021. It is ordered accordingly." 3. Mr. Sunil Agarwal, who appears on behalf of the contesting respondent, i.e., respondent no.2, says that prior to the issuance of the show-cause notice cum draft assessment order dated 02.04.2021, opportunities were granted to the petitioner which were not availed. 3.1 In this context, Mr. Agarwal says, an opportunity was granted, as far back as in December 2020. 3.2 Mr. Gautam Jain, on the other hand, says that what is in issue is: once a show-cause notice cum draft assessment order was issued to the petitioner, it was logical that the petitioner was required to respond to the same, and therefore, what happened prior to the issuance of the show-cause notice cum draft assessment order is not m....