2023 (5) TMI 1116

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....a says that he does not wish to file a counter-affidavit in the matter and that he will argue the matter based on the record presently available with the court. Therefore, with the consent of the counsels for the parties, the writ petition is taken up for final hearing and disposal at this stage itself. 3. The core issue, which the petitioner has raised before us is that the impugned assessment order dated 28.03.2022 concerning Assessment Year (AY) 2013-14 is based on an earlier assessment order passed vis-à-vis an entity going by the name 'Caruna Bal Vikas' [hereafter referred to as "CBV"]. The contention being that the Assessing Officer (AO) in passing the impugned assessment order has extracted only a part of the reassessment o....

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....n taken up for adjudication, causing detriment to the interests of the petitioner. 9. Mr Maratha says that since, concededly, CBV is an entity which has extended a sub-grant to the petitioner, in the ordinary course of things, the petitioner should have known about the reassessment order that was passed in the case of CBV. 9.1 The argument is that the petitioner has approached this court after a long lapse of time. In sum, Mr Maratha says that the petitioner is guilty of delay and laches. 10. We have heard the counsel for the parties. 11. According to us, the grievance of the petitioner is twofold. 11.1 First, the AO in the passing the impugned assessment order dated 28.03.2022 has taken recourse to a part of the reassessment....