2021 (9) TMI 1488

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....with Mr. Sameer Dalal i/b. Ms. Monika Walve. For the Respondents : Mr. Akhileshwar Sharma. ORDER 1. Petitioner is impugning assessment order dated 18th May 2021 passed under Section 143 (3) read with Section 144 B of the Income Tax Act, 1961("the said Act") by Respondent No.1 as well as the notice of demand dated 18th May 2021 issued under Section 156 of the Act and penalty notices dated ....

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.... (b) provide an opportunity to the assessee, in case any variation prejudicial to the interest of assessee is proposed, by serving a notice calling upon him to show cause as to why the proposed variation should not be made; or (c) ......." 2. Admittedly, there has been a variation prejudicial to the interest of assessee. In the affidavit in reply to the Petition, at paragraph 7, it is ....