2025 (7) TMI 679

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.... Adv. For the Respondents: Mr. Amit Sharma, Adv. Mr. Abhishek Kumar Agrahari, Adv. JUDGMENT PER RAJA BASU CHOWDHURY, J: 1. The petitioner seeks to challenge the assessment order dated 31st March, 2025 passed under Section 147 read with Section 254 of the Income Tax Act, 1961 (hereinafter referred to as 'the said Act') for the assessment year 2011-12 on the ground that the said assessme....

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....the assessment order as also the order passed by the Commissioner of Income Tax (Appeals) dated 31st March, 2022, restored the assessment proceeding to the file of the assessment officer for re-adjudication with a specific direction that the assessing officer shall grant sufficient time to the assessee for submitting requisite details and also commence investigation, if any, well in advance. 3.....

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....ed upon the petitioner to respond to the same on the following day at 6:00 P.M. According to the petitioner, the following day was a Sunday. The aforesaid time offered to the petitioner was not adequate for the petitioner to respond. Notwithstanding the above, the petitioner had duly responded to the same on the following working day being a Monday i.e. on 31st March, 2025. The Assessing Officer w....

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.... he would submit that considering the fact that the time to conclude the proceedings was till 31st March, 2025, a short period was offered. There is no irregularity in affording such short period having regard to limitation being involved. 6. Having heard the learned advocates appearing for the respective parties, I note that in the instant case the Appellate Tribunal had specifically directed ....