TMI Blog2023 (2) TMI 29X X X X Extracts X X X X X X X X Extracts X X X X ..... u/s 148 - as argued variation be not made without availing an opportunity or replying to the request of the petitioner - HELD THAT:- It is not being disputed that the opportunity of hearing is not granted. On the basis of the information received in respect of assessee, verification of material received from DDIT (Inv.) Unit-1(3), assessing officer has finalized the assessment order dated 12.3.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... S MEHTA FOR THE PETITIONER NOTICE SERVED FOR THE RESPONDENT ORDER PER : HONOURABLE MS. JUSTICE SONIA GOKANI 1. The petitioner is before this Court making a grievance against the respondents for not availing the opportunity of hearing with the following prayers: 7. In the above-said premises, the Petitioner prays that :- (A) This Hon'ble Court may be pleased to issue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 44 of the Income-Tax Act, 1961 and initiate the best judgment assessment on the count that the petitioner did not file the return of income in response to the notice under Section 148 of the Act. The variation was also proposed on account of sale of penny stock share. In response to the same, the petitioner on 3.3.2022 explained various details, the details which is not necessary to be gone into. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. On issuance of notice, the learned senior standing counsel Mr. Nikunt Raval appears. 6. It is not being disputed that the opportunity of hearing is not granted. On the basis of the information received in respect of assessee, verification of material received from DDIT (Inv.) Unit-1(3), assessing officer has finalized the assessment order dated 12.3.2022, which is impugned in the instance c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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