2023 (11) TMI 342

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..... P.C. Chhotaray. P.C. : 1. In the petition, in paragraph 4.3.1(v), petitioner has alleged that it had, in reply to notice under Section 142(1) of the Income Tax Act, 1961 (the Act), responded on 9th March 2021 and 16th March 2021 but thereafter, 2nd respondent for six months, until 3rd September 2021, did not take any steps. In response to a notice dated 3rd September 2021, petitioner filed v....

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....g a personal hearing because there was no time left to give personal hearing. It is most unfortunate stand being taken by Union of India through its officers which requires to be condemned, which we hereby do. We hope the CBDT would sensitize its officers so that they do not treat assessees in this manner. The least we would have expected in the affidavit in reply or atleast the counsel, as an off....

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....tioner, notice whereof shall be communicated atleast five working in advance. 4. Ms. Hariya states that as only three working days were given to respond to the draft assessment order, petitioner should be given liberty to file a supplementary response to the draft assessment order. Ms. Hariya is justified in making this request. Petitioner may, therefore, file a supplementary response to the draf....