TMI Blog2022 (5) TMI 284X X X X Extracts X X X X X X X X Extracts X X X X ..... ELD THAT:- Having heard learned counsel for the parties, this Court is of the view that even if the submission of learned counsel for the Respondents is accepted, then also the impugned assessment orders are liable to be set aside as the Petitioner was not given adequate opportunity to file response to the said show cause notice-cum-draft assessment orders. Consequently, as there has been a violat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hallenging the reassessment notices dated 27th March, 2021 and 28th March, 2021 issued under Section 148 of the Income Tax Act, 1961 [ the Act ] for the assessment years 2014-15 and 2015-16 as well as the assessment orders dated 30th March, 2022 passed under Section 147 read with Section 143(3) of the Act. 2. Learned counsel for the Petitioner states that the impugned notices as well as the ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and 16th December, 2017 have been passed accepting the same. 4. Learned counsel for the Petitioner further states that the impugned assessment order has been issued in violation of the principle of natural justice as the Petitioner was not given adequate opportunity of being heard. He points out that the Petitioner had not even been granted a day s time to respond to the show cause notice date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... roceedings. 7. Having heard learned counsel for the parties, this Court is of the view that even if the submission of learned counsel for the Respondents is accepted, then also the impugned assessment orders are liable to be set aside as the Petitioner was not given adequate opportunity to file response to the said show cause notice-cum-draft assessment orders. Consequently, as there has been a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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