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2024 (4) TMI 602

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..... t served on the petitioner, the same cannot be accepted, in view of the specific averment made in the assessment order regarding service of notices. Therefore, the contention taken by the petitioner is that, he was not given sufficient opportunity of being heard and the order in question is an ex-parte order, also cannot be accepted. Annexure-D was came to be passed on 19.03.2022 and before passing the order, several notices were issued to the petitioner. In spite of that, he has not chosen to appear before the authority and not complied the demand made therein. The next ground urged by the petitioner that the order in question was passed during Covid-19 also cannot be accepted. Under such circumstances, even though we do not find any reaso .....

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..... tax consultant for the purpose of filing the returns. The respondents proceeded to issue notices calling for the petitioner to produce documents and information under Section 142(1) of the Act. Notices as per Annexures-B, B1 and B2 were issued, but notices were not served on the petitioner and he could not give any reply. In the meantime, respondent No. 2 passed ex-parte assessment order, pursuant to the show-cause notice dated 08.03.2022, without providing adequate opportunity to the petitioner to represent his case. On the basis of the assessment order, the demand notice was also issued as per Annexure-F, on the basis of the computation sheet produced as per Annexure-E. Therefore, the learned counsel submitted that, if reasonable opportu .....

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..... no response. 5. During all these period, there was no waive of Covid-19 and therefore, no grounds are made out by the petitioner for granting the relief in his favour. Accordingly, he prays for dismissal of the writ petition. 6. However, learned counsel for the respondents submitted that if the court finds it necessary to afford one more opportunity to the petitioner, he may be directed to appear before the respondents, to enable the respondents to complete the procedure within the time bound manner. 7. Perused the materials on record. 8. The documents that are relied on by the petitioner disclose that respondent had issued various notices to the petitioner calling upon him to file his returns for the year 2014-15. Even though it is conten .....

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