TMI Blog2023 (12) TMI 1129X X X X Extracts X X X X X X X X Extracts X X X X ..... is peculiar circumstances he had no knowledge of the notice and as such, he has not filed any response to the notice issued u/s148A[b]. Thirdly , when a show cause notice under Section 142[1] of the IT Act is issued, the petitioner has responded asking for details and an opportunity of hearing. This Court must further observe that the necessary details will be provided when notice under Section 148A[b] of the IT Act is issued, but the notice under Section 148A[b] of the IT Act in the present case does not contain all the necessary details, and it could be that such information could not be sought for at the stage of Section 144B of the IT Act but an opportunity of hearing is contemplated at this stage under these provisions. The petitio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s (By Sri. M. Dilip, Advocate) ORDER The petitioner has impugned the assessment order dated 13.03.2023 under Section 147 read with Sections 144 and 144B of the Income Tax Act, 1961 [for short, the IT Act ] as per Annexure - A.1, the Computation Sheet dated 13.03.2023 as per Annexure A.2, the Demand Notice dated 13.03.2023 as per Annexure A.3 and the Penalty Notices dated 13.03.2023 as per Annexures - A.4, A.5 and A.6. 2. The petitioner, apart from these, has also impugned the adjudication order under Section 148A[d] of the IT Act dated 28.03.2022 as per Annexure B.2 and the consequential Notice dated 31.03.2022 under Section 148 of the IT Act as per Annexure - B.3. The petitioner has impugned the assessment order dated 13 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ls, Insurance Policy details and Post Office details, Date of such transactions, I will look into the same and try to recollect based on the details provided to me, I will be able to furnish the requisite details. In view of the above, I being a senior citizen humbly request your good selves to kindly transfer the case to the Tumakuru ITO if possible which will provide me another opportunity by providing the details and also further request to provide me a Video Conferencing Opportunity. If the adjudication order dated 28.03.2022 under Section 148A[d] is concluded on the basis that there is no response, the assessment order is completed recording that the petitioner has failed to support documentary evidence regarding the purcha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct. Secondly , the petitioner asserts that because of his peculiar circumstances he had no knowledge of the notice and as such, he has not filed any response to the notice issued under Section 148A[b]. Thirdly , when a show cause notice under Section 142[1] of the IT Act is issued, the petitioner has responded asking for details and an opportunity of hearing. This Court must further observe that the necessary details will be provided when notice under Section 148A[b] of the IT Act is issued, but the notice under Section 148A[b] of the IT Act in the present case does not contain all the necessary details, and it could be that such information could not be sought for at the stage of Section 144B of the IT Act but an opportunity of hearing i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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