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2022 (7) TMI 696 - HC - Income TaxReopening of assessment u/s 147 - procedure followed by the officer - Petitioner stated that the firm to which the notice has been sent is no longer in existence, as it has been succeeded by a company - HELD THAT:- As admitted position that the address of the firm and the company is one and the same. Thereafter, the Assessing Authority has once again issued notice under Section 142(1) of the Act on 09.03.2022 calling upon the company to respond by 11.03.222. Admittedly, the petitioners have not responded to this notice as well. It is in these circumstances that the impugned orders of assessment have come to be passed, on 30.03.2022, 31.03.2022 and 31.03.2022 respectively. No infirmity in the procedure followed by the Assessing Authority and also find that sufficient opportunity has been granted to the assessees to make their submissions and such opportunities have not been availed. The mere filing of letter dated 07.12.2021 will not exonerate the petitioners from not responding to the earlier and subsequent notices issued and it is of the considered view that no infirmity is made out warranting interference in the impugned orders under Article 226 of the Constitution of India.
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