2026 (2) TMI 1458

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....ent / Order / Decisions)<br>Dated:- 18-2-2026<br>WRIT PETITION NO. 5019 OF 2026 (T - IT) - -<br>Income Tax<br>THE HON&#39;BLE MR. JUSTICE S SUNIL DUTT YADAV FOR THE PETITIONER : SRI. S. SHANKAR, SENIOR ADVOCATE FOR SRI. VENKATESH G., ADVOCATE FOR THE RESPONDENTS : SRI. THIRUMALESH, ADVOCATE ORAL ORDER Learned counsel Sri. Thirumalesh, accepts notice for the respondents. 2. The petit....

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.....2024. It is submitted that such time limit of less than 7 days amounts to violation of principles of natural justice and is also in violation of the SOP applicable for faceless assessment. Reliance is placed on the order passed in W.P.No.12923/2023. 4. Learned counsel Sri. Thirumalesh, appearing for the revenue submits that while the petitioner has sought to assail the last of the show-cause n....

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.... the SOP applicable for faceless assessment, copy of which is produced at Annexure-T. 3. Attention is drawn to Clause N.1.3 which observes that the time for response to a show cause notice ought to be 7 days from the issue of show cause notice. He submitted that in the assessment order it was observed that there was no reply to the show cause notice and the Assessing Officer has proceed w....

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.... In light of violation of the applicable SOP at Clause N.1.3, the proceeding is required to be reopened. Though learned counsel for the revenue submits that the petitioner has not been diligent in participating in the previous proceedings, however, the question to be looked into is the show-cause notice at Annexure-F which is in issue. Irrespective of the previous proceedings, if the illegality is....