TMI Blog2022 (5) TMI 1425X X X X Extracts X X X X X X X X Extracts X X X X ..... in respect of the modus operandi, business, genuineness of the transaction and the creditworthiness of M/s. Winsome Commotrade Pvt. Ltd., there were lack of full-proof documents submitted by the petitioner in respect of the said entity. Accordingly, there was a need for cross-verification. There is no scope of interference with the impugned notice on the ground of violation of the principles of natural justice. The petitioner was issued two separate notices i.e. 22 March, 2022 and 5 April, 2022. The Reply of the petitioner has been dealt with in the impugned notice. The impugned notice records reasons. The impugned notice also records that due to lack of full proof documents submitted by the petitioner the modus operandi, the genuinenes ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9th April, 2022. It is also alleged that no personal hearing was afforded to the petitioner before the impugned notice was issued. On behalf of the respondent Revenue Authorities, it is submitted that despite two prior notices, the petitioner had deliberately and intentionally chosen not to participate in the proceeding. Moreover, it is alleged that the respondent authorities have dealt with the Reply dated 9th April, 2022 filed by the petitioner. In any event, at the stage of re-assessment of the proceeding, the petitioner would have an ample and adequate opportunity to contest the same. Hence, there is no question of interfering with the impugned notice. I find from the impugned notice that it is alleged by the respondent aut ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 22 March, 2022 and 5 April, 2022. The Reply of the petitioner has been dealt with in the impugned notice. The impugned notice records reasons. The impugned notice also records that due to lack of full proof documents submitted by the petitioner the modus operandi, the genuineness of transactions and the credit worthiness of M/s. Winsome Commotrade Pvt. Ltd. could not be substantiated. In view of the aforesaid, I find that there is no illegality nor infirmity in the impugned notice. I also find that the decision of Bishal Aswing Patel Vs. Assistant Commissioner of Income Tax (2022) SCCOnLine 366 is distinguishable. Similarly, the decision reported in Diya Capital Pvt. Ltd. Vs. Assistant Commissioner unreported decision in WP 7406 of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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