2022 (12) TMI 183

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....assessment issued under Section 147 of the Income Tax Act, 1961(for short the Act). 2. The grievance of the petitioner is that, sufficient opportunity was not granted to him to object to the proposed assessment, thereby violating the principles of natural justice. Petitioner contends that infringement of the aforesaid principles is glaring in the order of assessment and hence he has invoked the....

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....hat he had even filed his objections as evident from Ext.P8 reply notice, that too within the time granted. The learned counsel further contended that the objections raised by the petitioner were considered in the assessment order and hence this was not a fit case warranting interference under Article 226 of the Constitution of India, especially since petitioner has an effective remedy before the ....

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....t with by the assessing officer on merits, as is evident from Ext.P9 order and the same were rejected. 7. The jurisdiction of this Court under Article 226 of the Constitution of India does not warrant an appreciation of the merits of an order of assessment, for which an effective remedy is available before the Appellate Authority. Though the time limit provided to the petitioner was very short ....

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....e notice. Several steps precede the reply noticecollection of materials, verification of documents, appreciation of the allegations raised in the showcause notice, consultation with professionals etc. The aforesaid attributes that precede the preparation of response alone make an effective reply. When even minimal time to initiate the above mentioned steps is denied to assessees, this Court will b....