2022 (5) TMI 1105

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....ugh: Mr. Mani Bhadra Jain, Advocate. Respondent Through: Mr. Abhishek Maratha, senior standing counsel for the Revenue. J U D G M E N T MANMOHAN, J (Oral): 1. Present writ petition has been filed challenging the assessment order dated 23rd May 2021 and also notice of demand issued under Section 156 of the Income Tax Act, 1961 [for short 'the Act'] and notice for initiating penalty proc....

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....demic. He emphasises that for reasons beyond the Petitioner's control and in particular COVID-19 pandemic, non-accessibility to login credentials and material documents, unavailability of the Chartered Accountant, the Petitioner could not file objections and produce records and documents before the Respondent. He contends that the Respondent ought to have granted more time to the Petitioner for th....

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....Y 2018-19, I was unable to access the Income Tax E-Portal and as such, I did not file any response, document or exchanged any communication with the Respondent on the Income Tax E-Portal." 4. Learned Counsel for the Respondent states that the Petitioner/Assessee has an alternative efficacious remedy of filing an appeal before the Commissioner of Income Tax (Appeals) under Section 246 of the Act....

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....ficial records as they were maintained in his office at 211, Aditya Complex, C-3, Yamuna Vihar, Delhi-53 and he was unable to access them due to Covid-19 pandemic. 6. This Court also takes judicial notice of the difficulties faced by the society, in general, and the Assessees, in particular, in filing replies to show cause notices. This Court is further of the view that the filing of earlier re....