2024 (7) TMI 1189

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....dhoria ...For the respondents ORDER 1. The present writ petition has been filed, inter alia, challenging not only the show cause notice issued under Section 148A(b) of the Income Tax Act, 1961 (hereinafter referred to as the "said Act") dated 15th March 2024 for the assessment year 2017-18 but also the adjudication order dated 30th March 2024 passed under Section 148A(d) of the said Act for ....

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....portunity of personal hearing, no such opportunity of hearing was afforded to the petitioner. Independent of the aforesaid, the notice issued by the jurisdictional assessing officer under Section 148 of the said Act dated 30th March 2024 for the assessment year 2017- 18 has also been challenged on the ground that the same has not been issued as per the provisions of Section 151A of the said Act. ....

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....ce it appears that the petitioner had sought for an opportunity of personal hearing and despite making such request, the respondents had not afforded the same and having regard to the fact that a lesser period was given to the petitioner to respond to the show cause notice, I am of the view that the mater should be remanded back to the jurisdictional assessing officer for a decision afresh. 6. ....