TaxTMI 
TaxTMI 
2023 (3) TMI 866
X X X X Extracts X X X X
X X X X Extracts X X X X
....challenged the impugned assessment orders on the ground of violation of the principles of natural justice. A Show Cause Notice was received by the petitioner from the respondent on 10.05.2022 under Section 143(3) of the Income Tax Act. Under the Show Cause Notice, the petitioner was directed to submit the details and produce the documents mentioned therein and the petitioner was also directed to submit a reply on or before 17.05.2022. The petitioner submitted a reply on 17.05.2022 to the Show Cause Notice issued by the respondent dated 10.05.2022. Under the said reply, the petitioner has stated that since the documents/records sought for by the respondent in the Show Cause Notice are voluminous in nature, they have sought for two weeks time....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ed to the petitioner from the date of reply i.e. on 17.05.2022 and only thereafter, the impugned assessment orders dated 31.05.2022 have been passed. Therefore, he would submit that without exercising the statutory appellate remedy available to the petitioner if aggrieved by the impugned assessment orders, they have filed these writ petitions, which are not maintainable. 5.The contention of the learned Standing Counsel appearing for the respondent with regard to the limitation is disputed by the learned counsel for the petitioner, which is also reflected in the affidavit filed in support of these writ petitions. According to the petitioner, the limitation for passing the assessment orders will end only on 30.09.2022. 6.Admittedly, as seen....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... prejudice would be caused if the assessments are redone in respect of the assessment years 2019-20 and 2020-21. 8.However, it is made clear that apart from documents produced by the petitioner before this Court which according to the petitioner has satisfied the requirements of the respondent as per their Show Cause Notice dated 10.05.2022, the petitioner cannot furnish any further documents before the respondent and cannot protract the proceedings once the assessments are redone by the respondent pursuant to the directions given by this Court today. Since the reply dated 17.05.2022 sent by the petitioner to the Show Cause Notice dated 10.05.2022 has not been considered in the impugned assessment orders and that too when the petitioner ca....