2024 (1) TMI 1190

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....pearance: For the Petitioner(S) No. 1 : Mr B S Soparkar(6851)   For the Respondent(S) No. 1 : Mr. Varun K. Patel(3802)   ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA) 1. Heard learned advocate Mr. B.S. Soparkar for the petitioner and learned Senior Standing Counsel Mr. Varun K. Patel with learned advocate Mr. Dev D. Patel for the respondent. 2. By this peti....

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.... tax at Rs. 31,97,160/-. The assessment order was passed by the respondent under Section 143(3) read with Section 144B of the Income Tax Act, 1961 (for short 'the Act') assessing total income of the petitioner on 28.07.2021. 3.2. The respondent issued the show-cause notice under Section 148A(b) of the Act on 10.03.2022 for Assessment Year 2018-19 along with the details of the information on the....

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....ns of Section 148A(b) of the Act by granting further time not exceeding thirty days from the date on which the notice is issued and accordingly the respondent could not have passed the order under Section 148A(d) of the Act without giving opportunity of hearing. 5. Learned Senior Standing Counsel Mr. Varun Patel for the respondent fairly stated that the petitioner was not provided an opportunit....

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.... reply as provided under Section 148A(b) of the Act which reads as under : "Section 148A(b): provide an opportunity of being heard to the assessee, [***] by serving upon him a notice to show cause within such time, as may be specified in the notice, being not less than seven days and but not exceeding thirty days from the date on which such notice is issued, or such time, as may be extend....