2022 (12) TMI 1167

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....03.2021, the Petitioner was issued a notice under Section 148 by respondent no.1 stating that respondent no.1 has reasons to believe that income chargeable to tax for Assessment Year 2015-16 has escaped assessment. This notice required the Petitioner to file returns within 30 days. 4. Despite receipt of the above notice, the Petitioner did not bother to file any returns within 30 days. Almost eight months later, that is, on 03.01.2022, the Petitioner was served with a notice under Section 142(1) from ITI requiring the Petitioner to furnish accounts and documents to enable the respondents to proceed with the reassessment in terms of the notice dated 27.03.2021, which the Petitioner had not bothered to respond. 5. At this belated stage,....

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....s that the impugned notice/order must be set aside in such circumstances. 10. Ms S. Linhares counters the submissions made by Mr Panandiker. She submits that the Petitioner did not bother to file any returns for Assessment Year 2015-16 and, therefore, the provision of Section 147 of the IT Act was squarely attracted. She points out that the Petitioner did not bother responding to the notice dated 27.03.2021 within the prescribed period. She submits that the delayed return filed by the Petitioner was only to frustrate the time limits prescribed to the Assessing Officers for completing the assessment. She submits that there is clear information about the Petitioner receiving an amount of Rs. 2.74 crores and interest  of Rs.2,15,107/-.....