2023 (7) TMI 29

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....6761-62/2023 W.P.(C) 6837/2023 & CM Nos.26773-74/2023 W.P.(C) 6839/2023 & CM Nos.26775-76/2023 HON'BLE MR. JUSTICE RAJIV SHAKDHER And HON'BLE MR. JUSTICE GIRISH KATHPALIA Mr Kirti Uppal, Sr Adv. with Ms Kiran Kalra Uppal, Mr Prateek Solanki, Mr Nikhil Malhotra, Ms Shalini Bhardwaj and Mr Shekhar Kumar, Advs. for petitioner Mr Gaurav Gupta, Sr Standing Counsel with Mr Puneett Singhal an....

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.... learned senior standing counsel accepts notice on behalf of the respondents/revenue. 3. Given the order that we propose to pass, Mr Gupta says that counter-affidavit(s) need not be filed, and he will argue the above-captioned writ petitions, based on the record presently available to the Court. 3.1 Thus, with the consent of learned counsel for the parties, these writ petitions are taken up for ....

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....of principles of natural justice. 7. The record shows, that in each of the abovementioned cases, the petitioner was issued six separate notices of even date, i.e., 14.03.2023 under Section 153C of the Act. 7.1 Via these notices, the petitioner was given leave to file its return of income within 30 days. The said notices were followed by another set of notices, which were also six in number. Thes....

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....s on 12.04.2023, requesting the respondent to refrain from initiating penalty proceedings, there has been no movement in the matter. 10. Given this position, we are of the view, that the AO had put the petitioner on an extremely tight leash. The AO expected the petitioner to gather information for six AYs within two days, which by any yardstick was not a practical timeframe. 10.1 This is especia....