2023 (1) TMI 1293

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....dent : Mr. Anand Parchure, Advocate ORDER The petitioner is assailing the notice issued under clause (b) of section 148A of the Income Tax Act, 1961 (hereinafter referred to as 'Act' for short) and the order rendered in exercise of powers under clause (d) of section 148A of the Act. 02] The finding, which is recorded by the assessing authority, is that income to the tune of Rs. 74,73,800/....

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.... the Act came to be passed on the same date without giving any opportunity, whatsoever, to the assessee to show cause. 05] The respondents have filed affidavit in response dated 22/08/2022 asserting that the averment that the assessee received the notice only on 31/03/2022 at 1:45 p.m., is incorrect. The respondents have categorically stated that the notice dated 23/03/2022 was sent, and was du....

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.... delivered on the petitioner-assessee on 07:18:01 PM on 23/03/2022. The said notice is also sent by speed-post. After giving seven days time to the petitioner-assessee under section 148A(d) of the Act, orders were passed on 31/03/2022 with prior approval of the Principal CCIT, Nagpur and consequently, notice was issued under section 148 on 31/03/2022 with prior approval of PCCIT." 06] The averm....