9911796707
TMI Blog2024 (3) TMI 972X X X X Extracts X X X X X X X X Extracts X X X X ..... eared in this case: For the Appellant: Mr. Kamal Sawhney with Mr. Deepak Thackur & Ms. Aakansha Wadhwani, Advocates. For the Respondent: Mr. Rajeev Aggarwal, Additional Standing Counsel for R-1 & R-2 Mr. Anil Kumar Saxena, Senior Panel Counsel with Mr. Rajendra Rawat, G.P. for R-3 JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 23.12.2023, whereby the impugned Show ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... efaulters and tax non-payers. To the said Show Cause Notice, a detailed reply was furnished by the petitioner giving full disclosures under each of the heads. 4. The impugned order, however, after recording the narration, records that the reply uploaded by the taxpayer is not satisfactory. It merely states that "And whereas, the taxpayer had filed their objections/reply in DRC-06 and appeared per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his mind to the reply submitted by the petitioner. 6. Further, if the Proper Officer was of the view that reply was unsatisfactory and further details were required, the same could have been specifically sought from the petitioner. However, the record does not reflect that any such opportunity was given to the petitioner to clarify its reply or furnish further documents/details. 7. In view of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed under Section 75(3) of the Act.
9. It is clarified that this Court has neither considered nor commented upon the merits of the contentions of either party. All rights and contentions of parties are reserved.
10. The challenge to Notification No. 9 of 2023 with regard to the initial extension of time is left open.
11. Petition is disposed of in the above terms. X X X X Extracts X X X X X X X X Extracts X X X X
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