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2022 (5) TMI 301 - HC - Income TaxValidity of reopening of assessment u/s 147 - petitioner states that the impugned notices are void ab initio as they have been issued in the name of a non-existing partnership firm - Denial of natural justice - Petitioner had not been given an opportunity either to deal with or to respond to the show cause notices - HELD THAT:- Having heard the learned counsel for the parties, this Court is of the view that even if the submission of learned counsel for the respondent is accepted, then also the impugned orders are liable to be set aside as the Petitioner had not been given an opportunity either to deal with or to respond to the show cause notices dated 28th March, 2022 inasmuch as it had been issued after the date and time of compliance had expired. Consequently, the impugned orders are set aside on the ground of being violative of the principle of natural justice and the matter is remanded back to the Assessing Officer for fresh adjudication. The Petitioner shall file its response to the show cause notices dated 28th March, 2022 within four weeks.
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