2022 (12) TMI 1284

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....spondents. ORDER P.C. : 1. The petitioner challenges the Order of Assessment dated 18th September 2022, passed under Section 143(3), r/w. Section 144B, of the Income Tax Act, 1961, relevant to the Assessment Year 2020-21 primarily on the ground that the Show Cause Notice dated 13th September 2022, issued in terms of Section 144B sub-section (6), clause (vii) of the Act, did not provide to the p....

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....ot be so uploaded because the portal had been closed. It is further stated that the petitioner accordingly registered its grievance on the official portal and also uploaded along with the said grievance its objections to the proposed variation on 16th September 2022. Thereafter, the assessment order is stated to have been passed on 18th September 2022. 2. Counsel for the petitioner states that si....

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....en days in certain cases, keeping in view the limitation date for completing the assessment. 4. Affidavit-in-reply is tendered in court, which is taken on record. 5. In our opinion, the time that was made available to the petitioner to file its response to the show cause notice was quite inadequate and illusory and therefore, the principles of natural justice can be said to have been violated in....