2024 (1) TMI 497

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.....ITBA/PNL/S/270A/2022-2023/1050188736(1) in W.P.No.13871 of 2023 and the impugned Order dated 28.02.2023 bearing No.ITBA/AST/S/143(3)/2022-2023/1050188651(1) and the consequential notice dated 19.0.4.2023 bearing ITBA/PNL/F/270A/2023- 2024/1052197216(1) in W.P.No.13871 of 2023. 3. This is the second round of litigation before this Court. Earlier, the petitioner had challenged the Assessment Order dated 26.09.2022 on the ground that the petitioner was not given the opportunity of personal hearing. 4. The petitioner therefore filed W.P.No.27938 of 2022. By an order dated 19.10.2022, the said writ petition was allowed at the stage of admission with the following observations:- "Mr.A.P.Srinivas, learned Senior Standing Counsel ac....

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....in a period of four (4) weeks from date of conclusion of personal hearing. 6. Thus writ petition stands allowed. No costs. Connected Miscellaneous Petitions are closed." 5. Pursuant to the aforesaid order dated 19.10.2022, the petitioner was issued with a Show Cause Notice dated 11.01.2023 to which, the petitioner has also replied on 12.01.2023, which is now culminated in the impugned Assessment Order dated 28.02.2023. 6. Pursuant to the impugned Assessment Order dated 28.02.2023, the petitioner has also been issued with the Notice under Section 156 of the Income Tax Act, 1961, whereby the petitioner has been called upon to pay a sum of Rs. 29,54,58,896/-. 7. A detailed submission was made by the petitioner on mer....