2024 (10) TMI 175

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....x<br>THE HONOURABLE MR.JUSTICE SENTHILKUMAR RAMAMOORTHY For the Petitioner: Mr.A.S.Sriraman For Respondents: Mrs.S.Premalatha, Jr. SC 1, 3 For Respondent 2: Dr.B.Ramaswamy, Sr. SC ORDER An assessment order dated 26.03.2024 is challenged on the ground of breach of principles of natural justice. The petitioner filed the return of income for assessment year 2022-23 on 30.12.2022 by dec....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... in these facts and circumstances. 2. Learned counsel for the petitioner pointed out that the show cause notice proposing the variation was issued on 19.03.2024 calling upon the petitioner to show cause on or before 20.03.2024. In spite of a request for further time, he submitted that the time was extended by only one day. Within the limited time, he pointed out that the petitioner submitted a ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the details of opportunities provided, she submits that the impugned order was preceded by three notices under Section 143(2) and Section 142(1). Therefore, she contends that reasonable opportunity was provided to the petitioner. 4. The show cause notice dated 19.03.2024 calls upon the petitioner to show cause on or before 20.03.2024 by enclosing all supporting documents such as bills, voucher....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... and added back to the income of the assessee u/s 69C r.w.s 115BBE of the Act. Further I am satisfied that assessee is liable for penalty u/s 271AAC on account of addition made u/s 69C of the Act. I therefore initiate penalty u/s 271AAC of the Act." 5. From the above extracts, it is evident that the respondents refused to provide further time since the limitation period expires on 31.03.2024. B....