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TMI Blog2024 (1) TMI 1190X X X X Extracts X X X X X X X X Extracts X X X X ..... No. 1 : Mr B S Soparkar(6851) For the Respondent(S) No. 1 : Mr. Varun K. Patel(3802) ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA) 1. Heard learned advocate Mr. B.S. Soparkar for the petitioner and learned Senior Standing Counsel Mr. Varun K. Patel with learned advocate Mr. Dev D. Patel for the respondent. 2. By this petition under Article 226 of the Constitution ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt under Section 143(3) read with Section 144B of the Income Tax Act, 1961 (for short 'the Act') assessing total income of the petitioner on 28.07.2021. 3.2. The respondent issued the show-cause notice under Section 148A(b) of the Act on 10.03.2022 for Assessment Year 2018-19 along with the details of the information on the basis of which the respondent believed that the income chargeable to tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ays from the date on which the notice is issued and accordingly the respondent could not have passed the order under Section 148A(d) of the Act without giving opportunity of hearing. 5. Learned Senior Standing Counsel Mr. Varun Patel for the respondent fairly stated that the petitioner was not provided an opportunity of hearing and the matter may be remanded back to the respondent-Assessing Offic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 148A(b): provide an opportunity of being heard to the assessee, [***] by serving upon him a notice to show cause within such time, as may be specified in the notice, being not less than seven days and but not exceeding thirty days from the date on which such notice is issued, or such time, as may be extended by him on the basis of an application in this behalf, as to why a notice under section 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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