TaxTMI 
TaxTMI 
2026 (9) TMI 1553
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....on 156 of the Act dated 11th March 2026, and the Show Cause Notices for levy of penalty, all dated 11th March 2026, for Assessment Year 2018-19, whereby the total income of the Petitioner was assessed at Rs. 75,05,130/- and a demand of Rs. 1,42,35,470/- was raised. 3. In this Petition, the Petitioner has also challenged the validity of the Notice issued under Section 148 of the Act dated 24th August 2024 as well as the constitutional validity of the provisions of Section 147A of the Act. However, the learned Counsel for the Petitioner, on instructions, states that at present he wants to press his challenge against the Assessment Order and the consequential Notice of Demand and Show Cause Notices for levy of penalty. He submitted that all....
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....y 2026 to 12th February 2026. It has been pleaded in the Petition in paragraph 3.17 that there was no rescheduling of the VC, and directly the Assessment Order was passed on 11th March 2026. The Assessment Order at page 214 points out that notice of hearing was issued on 6th February 2026 and 13th February 2026. However, the Petitioner has pleaded in the Petition that no such Notices were ever received, and to this effect, a screenshot of the portal has been attached at page 205 of the paper book which consists of all the Notices issued for a personal hearing. From the said screenshot, it can be seen that only two Notices of personal hearing were issued, the last being of 3rd February 2026 calling upon the Petitioner to appear on 5th Februa....
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....se, no such personal hearing was granted. Therefore, we are satisfied that the present Petition would require interference, and we accordingly do so. The Assessment Order dated 11th March 2026, the Notice of Demand dated 11th March 2026 and the Show Cause Notice for penalty of the same date are accordingly quashed and set aside. 8. The matter is now remanded to the file of the Assessing Officer. He shall issue a Notice to the Petitioner informing him that the portal has been opened. The Petitioner, if he wants to file any further Reply, can file the same within seven days thereafter. The Petitioner, thereafter, shall be issued a Notice of personal hearing granting at least three working days' time to the Petitioner to appear before t....