2025 (2) TMI 874

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....'BLE MR. JUSTICE TUSHAR RAO GEDELA For the Petitioner Through: Mr. Nitin Kanwar, Advocate. Respondents Through: Mr. Puneet Rai, SSC with Mr. Ashvini Kumar, Advocate and Mr. Rishabh Nangia, JSC. JUDGEMENT TUSHAR RAO GEDELA, J : (ORAL) 1. Present writ petition has been filed under Article 226/227 of the Constitution of India seeking quashing of the impugned notice dated 21.08.2024....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....g less time to the petitioner to file a reply not only violates provision of Section 148A (b) of the Act, but also violates principles of natural justice. 3. It is further stated that the petitioner approached the respondent personally to submit his reply under Section 148A (c) of the Act, on 27.08.2024 at Civic Centre, Minto Road, New Delhi - 110002, because there was no reply option available....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... by the petitioner, holding that it is a fit case for issuing a notice under Section 148 of the Act for AY 2018-19. The AO also proceeded to issue a notice under Section 148 of the Act. 5. Learned counsel appearing for the Revenue fairly states that the petitioner may be given one more opportunity to respond to the notice dated 21.08.2024. 6. In view of the above, the impugned order dated 31....