2026 (7) TMI 143

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....ANAVATI Appearance: For the Petitioner(s) No. 1: Mr Manish J Shah (1320). For the Respondent(s) No. 1,2,3: Mr Dev D. Patel, For Ms Maithili D Mehta (3206).   ORAL ORDER (PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA) 1. Since short issue is involved in the present writ petition, the same is taken up for hearing and is being decided by this order today. 2. The petitioner, in t....

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....ection 156 of the Act, deserve to be quashed and set aside on the ground that no adequate and reasonable opportunity was afforded to the petitioner to respond to the show cause notice dated 06.03.2026. 4. Learned advocate Mr. Shah, appearing for the petitioner has further submitted that a demand of Rs. 13,53,24,800/- has been raised against the petitioner by making an addition of Rs. 13,30,61,6....

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....o the show cause notice cannot be regarded as reasonable, and consequently, the impugned assessment order as well as the demand notice deserve to be set aside as having been passed in breach of the principles of natural justice. 5. In support of the aforesaid submissions, learned advocate Mr. Shah has placed reliance upon the decision of this Court dated 20.12.2021 rendered in Special Civil App....

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.... granted less than two clear days, which included Saturday and Sunday, to respond to the show cause notice dated 06.03.2026 issued under Section 144B of the Act. 8. Thus, in our opinion, the time granted to the petitioner to furnish its reply to the show cause notice cannot be said to be reasonable. We, therefore, find that there has been a breach of the principles of natural justice. 9. Add....