2022 (6) TMI 1506

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....lant : Mr. Vikash Singh, Ms. Sneha Singh and Mr. R. N. Bandyopadhyay For the Respondent : Mr. S. Roy Chowdhury JUDGMENT (Judgment of the Court was delivered by T.S. SIVAGNANAM, J.) 1. By consent of the parties, we take up the appeal itself for hearing and disposal. 2. This intra-Court appeal is directed against the order dated 26th April, 2022 in W.P.A. No.6938 of 2022. The appellan....

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....sing Officer. 4. The learned Single Bench opined that the appellants have not challenged the constitutional validity of any statutory provision and that there is no violation of principle of natural justice and the assessment order being an appealable order, did not entertain the writ petition and the same was dismissed. Aggrieved by the same, the appellants had filed the present appeal. 5. ....

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....s Court. Though such averment has been made, no particulars have been given as to on what date the appeal was filed before the CIT (A) nor the stage of the present appeal. 7. The learned Advocate appearing for the appellants, on specific instruction from his client, would submit that the appellants had never filed an appeal and moved the writ Court seeking for an opportunity to go before the As....

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....he view that ends of justice would be met if an opportunity is granted to the assessee to go before the Assessing Officer. However, for such reason, we are not inclined to quash the assessment order dated 23rd March, 2022, which shall be treated as draft assessment order and the appellants shall be permitted to put in their objections within a period that will be indicated by the Assessing Officer....