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2022 (4) TMI 1429 - HC - Income TaxReopening of assessment u/s 147 - assessee challenges the impugned notice as in view of Section 148A(b seven days time should have been given in the notice for responding the same, while according to the petitioner, in this case, six days time has been given and no opportunity of hearing was given as per the aforesaid provisions - HELD THAT:- Since the impugned notice was served through e-mail, so, on the date of e-mail, petitioner has already received the impugned notice and if that date is taken into account, then time to give reply by 23rd March if considered comes to seven days. Apart from these facts on going through the reasoning recorded in the order of rejection of the petitioner’s objection to the notice under Section 148A(b) The order under Section 148A(d) of the Act dated 29th March, 2022 does not deserve any interference. Furthermore, rejection of the petitioner’s objection to 148A notice does not mean that any final re-assessment order has been passed and demand has been raised. Petitioner will have ample opportunity during the reassessment proceedings to establish his case and to make out a case for dropping of proceeding under Section 148 of the Act. This case also cannot be called a case of violation of principles of natural justice, so far as merit discussed in the rejection order cannot be gone into by this writ court.
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