Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2023 (7) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (7) TMI 29 - DELHI HIGH COURTValidity of assessment u/s 153C - petitioner was issued six separate notices of even date u/s 153C - petitioner had asked for 30 days to respond to the said notice - HELD THAT:- As via notice dated 14.03.2023, 30 days’ time had been granted to file the return.Unfortunately for the petitioner, the AO passed the impugned assessment orders dated 28.03.2023, without granting the time sought for by the petitioner. Although representations were made thereafter by the petitioner for each of the assessment years on 12.04.2023, requesting the respondent to refrain from initiating penalty proceedings, there has been no movement in the matter. Given this position, AO had put the petitioner on an extremely tight leash. AO expected the petitioner to gather information for six AYs within two days, which by any yardstick was not a practical timeframe. This is especially so, as the AO, while issuing notice under Section 153C of the Act, had granted 30 days to the petitioner to file the return of income concerning the AYs in issue. Thus, for the foregoing reasons, we are inclined to set aside the impugned assessment orders.
|