TaxTMI 
TaxTMI 
2023 (10) TMI 273
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....run Karthik Mohan For the Respondent : Mr.B.Ramaswamy Senior Standing Counsel ORDER Heard the learned counsel for the petitioner and the learned Senior Standing Counsel for the respondent. 2. The petitioner has challenged the impugned Assessment Order dated 26.12.2021 passed under Section 143(3A) and 143(3B) of the Income Tax Act, 1961 for the Assessment Year 2018-2019 . 3. The challenge to t....
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....have any records to show that the show cause notice and the draft assessment order generated in the e-proceedings in the ITBA module, was indeed delivered as the delivery status of the petitioner 's e-mail id was not available. In para 4 of the counter, the respondent has further stated that the respondent is neither able to confirm nor deny the service of the show cause notice and draft asses....
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....ent proceedings in accordance with law". 8. The defence of the respondent was that the respondent is categorical as the respondent is unable to confirm the service of draft order and show cause notice on the petitioner as there are no records available with the respondent regarding the service of notice. 9. In this connection, a reference can be made to Section 4 of the Contract Act, 1872. As pe....