TMI Blog2022 (6) TMI 29X X X X Extracts X X X X X X X X Extracts X X X X ..... titions were filed and the same were allowed by a separate order passed by this Court today, where, after setting aside those assessment orders, matters were remitted back to the Assessing Authority with a direction to issue fresh show cause notice by giving not less than one week time to the petitioner assessee to respond. Therefore, the said directions issued by this Court shall be scrupulously followed and executed punctually by the respondent Assessing Authority. Therefore, at this juncture, the present challenge made against the 148 notice or the rejection order with regard to the objections raised by the petitioner for the proposed opening of assessment under Section 147 may not stand in the way. If any additional reasons have b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d orders rejecting the said objections raised by the assessee by orders dated 06.01.2022 and 13.12.2021. Challenging these proceedings, the present Writ Petitions have been filed. 4. It is brought to my notice by Mr.Srinath Sridevan, learned counsel appearing for the petitioner that, subsequently, a notice under Section 144A read with Section 142(1) was issued, pursuant to which, time limit was given on or before 23:59 hours on 28.03.2022 to reply. 5. But before making such reply, the website was closed as the petitioner could not have the access and on top of it on the same date i.e., 28.03.2022 by 23:26 hours i.e., well before the closing time for filing reply given to the petitioner, the Assessing Authority passed the order of asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he contended. 9. I have considered the rival submissions made by the learned counsel appearing on both sides and perused the materials placed before this Court. 10. As has been rightly pointed out by the learned Senior Standing Counsel appearing for the respondent Revenue, assessment orders were passed under Section 147 of the Act, prior to which, 148 notice was issued and the objections were raised, which were rejected through the impugned order. Challenging the assessment orders writ petitions were filed and the same were allowed by a separate order passed by this Court today, where, after setting aside those assessment orders, matters were remitted back to the Assessing Authority with a direction to issue fresh show cause notice by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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