TMI Blog2020 (9) TMI 1131X X X X Extracts X X X X X X X X Extracts X X X X ..... website and thus had not come to its attention - HELD THAT:- There is no serious dispute to the position that the show cause notice dated 06.11.2019 has only been uploaded and not served by e-mail. Petitioner has not been granted an effective opportunity to state its case before the AO - it is only at the stage of show cause notice that the issue to be decided in assessment is crystallised and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nior Standing Counsel for the respondent. 2. The challenge is to an order of assessment dated 19.11.2019 passed under the provisions of the Income Tax Act, 1961 (in short Act ) for the assessment year 2014-15. 3. Though the petitioner has raised various grounds in the writ petition, the preliminary ground agitated and pursued before me is the violation of principles of natural justice on th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e before the Assessing Officer. It is relevant to note that it is only at the stage of show cause notice that the issue to be decided in assessment is crystallised and communicated to the assessee and it is thus incumbent upon the Officer to have ensured that such notice was properly served and sufficient time granted to the assesse to respond prior to finalisation of assessment. 6. In the ligh ..... X X X X Extracts X X X X X X X X Extracts X X X X
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