2026 (9) TMI 1558

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....d under Section 143(3) read with Section 144B of the Income Tax Act, 1961 (for short 'the IT Act'), (ii) the notice of demand dated 3rd March 2026 under Section 156 and (iii) the penalty notices dated 3rd March 2026 issued under Sections 270A and 271AAC(1) of the IT Act. The Assessment Year is A.Y. 2024-25, in which the total income of the Petitioner was assessed at Rs.13,48,19,050/- and a demand of Rs.11,53,21,080/- is raised. 3. The short ground on which a challenge has been laid to the Assessment Order [and the consequential notices] is that the same has been passed in gross violation of the principles of natural justice and in violation of the provisions of Section 144B of the IT Act read with the Standard O....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... Further, penalty proceedings were initiated by issuing notice under Section 270A of the Act dated 3rd March 2026 (which was digitally signed on 5th March 2026, at 19:30:56 IST, i.e. before the passing of the Assessment Order) for under-reported income which is in consequence of misreporting thereof, as per the details given in the Assessment Order. Further, penalty proceedings were initiated by issuing a notice under Section 271AAC(1) of the IT Act (which has been digitally signed on 5th March 2026 at 22:36:51 IST, i.e. before the passing of the Assessment Order) for income determined under the provisions of Section 115BBE of the IT Act. 7. The Petitioner pointed out to us that he, being unaware that his adjournment request (made vide ....