2022 (6) TMI 1523

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....>Hon'ble Shri Justice Arvind Singh Chandel For Petitioner : Shri Siddharth Dubey, Advocate For Respondent No.1 : Shri Sumit Singh, Advocate For Respondents No.2&3 : Shri Ajay Kumrani, Advocate on behalf of Shri Amit Chaudhary, Advocate Order on Board 1. With the consent of Learned Counsel appearing for the parties, the matter is heard finally. 2. The instant petition has been....

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.... show-cause notice gave just 7 days' time to the Petitioner to file its reply. The Petitioner was unable to file reply to the notice as the transaction in question related to the financial year 2014-15 and the time was short. Thereafter, order dated 4.4.2022 (Annexure P2) was passed under Section 148A(d) of the Act and a notice was issued under Section 148 of the Act initiating re-assessment proce....

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....y Respondent No.2 as per Section 148A of the Act before issuance/passing of the notice/order under Section 148A(b), Section 148A(d) and Section 148 of the Act in the present case, but the same has not been done. Therefore, it is prayed by the Learned Counsel that the order dated 4.4.2022 (Annexure P2) and the notice dated 5.4.2022 (Annexure P3) be quashed and the Respondents be directed to afford ....

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....eply to the said notice. The time granted to the Petitioner/assessee to submit reply to the said notice appears to be unreasonable short and the Petitioner/assessee cannot be blamed for not being able to file the reply within such a short period. Thus, it appears that there is a violation of principle of natural justice. Therefore, the prayer made on behalf of the Petitioner/assessee appears to be....