2023 (7) TMI 1550

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..... Advocate For the Opposite Party : Mr. S. S. Mohapatra, Advocate (Senior Standing Counsel, I.T.) ORDER 1. Mr. Ray, learned senior advocate appears on behalf of petitioner (assessee) and demonstrates, the show cause notice was issued on 12th December, 2022 requiring reply by late afternoon of 16th December, 2022. This was contrary to direction by Central Board Direct Taxes (CBDT) for ther....

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....-cause. The assessee could have complied with the notice if wanted to. Further, as mentioned in clause no. N.1.3.2 Response time of 7 days may be curtailed, keeping in view the limitation date for completing the assessment. Hence, technically there is no violation of the SOP issued by the CBDT on this behalf." 3. Mr. Ray disputes alleged omission can be fatal to contention of his client. 4. ....