2022 (5) TMI 859

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....etitioner: Mr.Ved Kumar Jain, Advocate. Respondents: Mr.Ajit Sharma, senior standing counsel for the Revenue. JUDGMENT MANMOHAN, J (Oral): 1. Present writ petition has been filed challenging the reassessment notice dated 28th March, 2021 issued under Section 148 of the Income Tax Act, 1961 ['the Act'] for the assessment year 2015-16. The petitioner also seeks to challenge the assessment or....

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.... that the income alleged to have escaped assessment has been offered to tax in the hands of the amalgamated entity and an assessment order dated 16th December, 2017 has been passed accepting the same. 4. Learned counsel for the Petitioner further states that the impugned assessment order has been issued in violation of the principles of natural justice as the Petitioner was not given an opportuni....

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....es, this Court is of the view that even if the submission of learned counsel for the Respondents is accepted, then also the impugned assessment order is liable to be set aside as the Petitioner had no opportunity to deal with or respond to the show cause notice dated 28th March, 2022 as it had been issued after the date and time of compliance had expired. 8. Consequently, the impugned assessment ....