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TMI Blog2023 (7) TMI 286X X X X Extracts X X X X X X X X Extracts X X X X ..... s Through: Mr Sanjay Kumar, Sr Standing Counsel with Ms Easha Kadiyan and Ms Hemlata Rawat, Advs. RAJIV SHAKDHER, J. (ORAL): 1. Issue notice. 1.1 Mr Sanjay Kumar, learned senior standing counsel, accepts notice on behalf of the respondents/revenue. 2. Given the directions that we propose to issue, Mr Kumar says that he does not wish to file a counter-affidavit, and he will argue the matter b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the initial return, and thereafter, on the return filed pursuant to the notice issued under Section 148 of the Act. 6. The record shows that the petitioner was issued show cause notices dated 15.03.2023 and 02.05.2023, at the following e-mail address: "[email protected]" [See Annexure P-12 & Annexure P-13 appended on pages 314 and 315 of the case file]. 7. To be noted, the returns f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sued statutory show cause notices to the petitioner at the e-mail address, which was clearly not in use. The record reveals that the AO was aware of the e-mail addresses that the petitioner was using. 12. Given this position, Mr Kumar cannot but accept, that the requirement to serve statutory show cause notice, before taking recourse to best judgment assessment, has not fructified. The first prov ..... X X X X Extracts X X X X X X X X Extracts X X X X
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