9911796707
TMI Blog2024 (8) TMI 181X X X X Extracts X X X X X X X X Extracts X X X X ..... USTICE DINESH KUMAR SINGH FOR THE PETITIONER : BY ADVS. K. I. MAYANKUTTY MATHER R. JAIKRISHNA FOR THE RESPONDENT : BY ADVS. P. K. RAVINDRANATHA MENON (SR.) P.G.JAYASHANKAR JOSE JOSEPH, SC, INCOME TAX DEPARTMENT, KERALA KEERTHIVAS GIRI JUDGMENT Dated this the 22nd day of February, 2024 The petitioner who is a Non-resident Indian, an assessee under the provisions of the Income Tax Act and R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The petitioner choose not to respond to the said letter also. 3. 24.12.2019 was the last date for the response as per Ext.P6, the said letter was also duly delivered to the email address of the petitioner. Despite these opportunities, the petitioner did not file any reply, and thereafter, the order was passed on 25.12.2019. 4. Learned counsel for the petitioner submits that the last notice was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the last notice, the petitioner filed reply on 26.12.2019. However, before the reply could be reached, the impugned assessment order came to be passed. Therefore, the petitioner cannot make any grievance in respect of not having been afforded the opportunity as alleged or otherwise. The petitioner was afforded enough opportunities, but failed to avail the opportunity granted and therefore, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oner has failed to avail an opportunity of hearing, despite having been served with notices. Therefore, the petitioner probably cannot contend that he was not afforded an opportunity of hearing. 9. So far as the question of giving an opportunity of hearing by the Revisional Authority is concerned, though Section 264 of the I.T Act does not specifically provides giving an opportunity of hearing, b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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