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2022 (7) TMI 439 - HC - Income TaxReopening of assessment u/s 147 - notice under Section 148 A (b) to correct address or not? - HELD THAT:- As petitioner has not been able to make out a case that the address on which the notice under Section 148 A (2) (b) sent was not one in the ITR furnished by the assessee to which the communication related. Moreover, in the absence of the ITR for assessment year 2021-22, the department cannot also be blamed for sending the e-mail notice on the address indicated in the ITR 2020-21 assessment year. We are also of the opinion that such communication could have been delivered or transmitted electronically on any of the e-mail addresses made available by the addressee to the Income Tax Authority including the one on which he has filed ITR 6 for assessment year 2020- 21 on which such notice under Section 148 A (b) has been delivered. We may also passingly observe that considering the strict time line stipulated for a preliminary enquiry under Section 148A before re-opening assessment proceedings, interference on such issues at this stage, when facts and documents on record do not substantiate the contention of the petitioner, are wholly uncalled for.
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