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2023 (8) TMI 1284 - HC - Income TaxTime limit for completion of assessments and reassessment u/s 153 - Extension of period of limitation after Covid - Validity of Notice calling the petitioner for a hearing challenged in a remand back proceedings - HELD THAT:- This Writ Petition challenging the hearing notice dated 26.02.2020 fixed, pursuant to the ITAT's order dated 20.06.2019, is without any merits. By the impugned order, the petitioner was called upon to come for a personal hearing on 05.03.2020. The said notice fixed the hearing on 05.03.2020. The hearing did not take place on account of out break of Covid-19 pandemic. In any event, the petitioner appears to have sent representation on 12.05.2022 requesting for a personal hearing and reminder dated 28.06.2023, even though according to the petitioner the limitation would have expired on 30.06.2021 in terms of the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. There is no merits in the challenge to the impugned notice. It is however open for the petitioner to send appropriate representation to the effect that the proceedings initiated for the AY 2014-2015 have abated in accordance with Section 153(3) read with proviso to the aforesaid Section of the Income Tax Act, 1961 and the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Writ Petition is disposed of. Since the petitioner has sent the reminder representation on 28.06.2023, the first respondent shall consider and pass a preliminary order based on the petitioner's representation regarding the limitation
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