TMI Blog2022 (12) TMI 115X X X X Extracts X X X X X X X X Extracts X X X X ..... limitation even if the date of receipt of notice is determined to be any other date other than 25-03-2022. The petitioners have a statutory right to reply to the notices within 7 days of its receipt. Though there is substantial merit in the contention taken by the learned counsel for the department that the notices having been sent to the registered Email Ids of the assessees on 25-03-2022 that, m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etitioners in these cases are assessees under the Income Tax Act. Since identical issues arise for consideration in these cases and they can be conveniently disposed of by the common judgment. 2. In both these cases the petitioners were issued with notices under Section 148 A of the Income Tax Act, requiring the petitioners to show cause as to why reassessment proceedings should not be initiate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... emently opposes the grant of any relief. It is submitted that even assuming that the physical copies of the notices were received by the respective assessees only on the dates specified above, it cannot be said that sufficient notice as required by the provisions Section 148A were not given as the notices were uploaded in the system and were sent to the registered Email Ids of the respective asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t to the registered Email Ids of the assessees on 25-03-2022 that, must be taken as a relevant date, I am of the opinion that no prejudice will be caused to the department by affording an opportunity to the petitioners to reply to the show cause notice within a period of 7 days. In the result Ext.P3 order in both cases will stand set aside and the officer concerned shall take a fresh decision in t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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