2023 (10) TMI 1462

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... with Mr. Ashwin Jain i/by Ms. Radha Halbe for the Petitioner Mr. Suresh Kumar for the Respondents-Revenue PC:- 1. Petitioner is impugning an assessment order dated 26th March 2022 passed under Section 147 read with Section 144 read with Section 144B of the Income Tax Act, 1961 ("the Act") on the principal ground that no notice was issued prior to passing the assessment order. It is Petit....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....to explain by serving the notice upon Petitioner. If email id was not available in the portal, it should have been served physically upon Petitioner at least by courier or speed post and acknowledgment filed. There have been SOPs in place and the last one which is in force before the assessment order was passed is dated 23rd November 2020. After the assessment order was passed, a fresh/revised SOP....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ich the letter is sent, speed post tracking ID, date on which letter is sent, mobile number on which SMS is sent along with the date and time of sending, will be updated in the database accessible to AU on Insight; G.3.3 To ensure completeness of record, the AU shall enter all the details referred in Para G.3.2 above, along with the date of delivery, if any, of the Speed Post letter in th....