TMI Blog2021 (9) TMI 871X X X X Extracts X X X X X X X X Extracts X X X X ..... proceedings, response acknowledgment of the department. There is no reference to this reply in the impugned order. Thereafter petitioner received another notice dated 17th January 2020 under Section 142(1) of the Act to which according to petitioner, a reply dated 23rd January 2020 has been filed. It is Respondent s case that it was filed only on 30th April 2021 and not on 23rd January 2020. Petitioner later received a notice dated 12th February 2020 under Section 142(1) followed by a reminder dated 14th December 2020. Admittedly, no response was filed by petitioner to these two notices. Petitioner thereafter received a notice dated 7th April 2021 to which a partial response has been filed on 30th April 2021. In view of this background, for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R.I. CHAGLA, JJ. Mr. Ramesh Ramamurthy a/w Mr. Saikumar Ramamurthy for the Petitioner. Mr. Suresh Kumar for the Respondent. (V.C.) ORDER : 1. Petitioner is impugning the assessment order dated 30 th April 2021 for assessment year 2018-19 on the grounds that the same has been passed without application of mind and on incorrect reasons. 2. In the assessment order it is stated as under:- Notices u/s 142(1) dated 17/1/2020, 12/2/2020 and 7/4/2021 and reminder dated 11/11/2020 and 14/12/2020 was left unheeded, even though a statutory notice mandates utmost compliance. Since the assessee was not responsive, the case was referred to Verifcation Unit for physical service of notice. The VU has reported vide reports ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ary 2020. Petitioner later received a notice dated 12th February 2020 under Section 142(1) followed by a reminder dated 14th December 2020. Admittedly, no response was filed by petitioner to these two notices. Petitioner thereafter received a notice dated 7th April 2021 to which a partial response has been filed on 30th April 2021. In view of this background, for the Assessing Officer to say that the notices issued by respondents under Section 142(1) of the Act were left unheeded or the assessee was unresponsive is not correct. 4. For respondent to also say that the verification unit for physical service of notice reported that petitioner could not be located in the three addresses also is not acceptable because petitioner is a company r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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