2024 (9) TMI 1757

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....Mr. Justice Partha Sarthy For the Petitioner/s : Mr. Chiranjiva Ranjan, Advocate For the Respondent/s : Mrs. Archana Sinha @ Archana Shahi, Sr. Counsel ORDER The petitioner is aggrieved with Annexure- 5 order passed under Section 148A(d) of the Income Tax Act, 1961. 2. The specific contention of the petitioner is that the petitioner's reply was not considered and later extension of ....

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....petition. But the petitioner does not speak of the date on which he received Annexure-3, which has been produced along with the writ petition. Annexure-4 reply is said to have been filed on 22.04.2023, which is admitted by the department in the counter affidavit; but after the order was passed. 6. The decision relied on by the learned Counsel for the petitioner found that the Assessing Officer ....

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....ation of the reply received was also found to have vitiated the order challenged therein. The instant case differs on facts distinctly. 8. The petitioner as has been noticed, submits that Annexure- 3 was never received by him but produced it along with the writ petition. Likewise, Annexure- 4 reply is said to have been filed on 22.04.2024, after the order was passed. The petitioner was granted ....