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TMI Blog2017 (3) TMI 147X X X X Extracts X X X X X X X X Extracts X X X X ..... s. Saloni Singh, Advocates. Respondents Through: Mr. Sanjay Kumar, Jr. Standing Counsel. O R D E R Issue notice. Mr. Sanjay Kumar, Advocate accepts notice on behalf of the Revenue. The petitioner is aggrieved by the order dated 20.12.2016 made under Section 147/143 (3) of the Income Tax Act, 1961 ("the Act"). Its grievance is that it was not given proper opportunity of hearing and was a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s: - "After some hearing, Mr. Rajesh Mahna, counsel for the petitioner has sought liberty to withdraw the writ petition and urge contentions with respect to the reopening of the assessment before the revenue authority. Liberty granted. The writ petition along with the pending applications is dismissed as withdrawn." The Revenue had, in the meanwhile, before the petitioner approached this Court, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as with the closure of the Central Excise proceedings, the rationale for reassessment seized to exist. It is contended that the AO's order - framing the assessment under Section 143 (3) on 20.12.2016 by completely ignoring these events and also not furnishing adequate opportunity to the petitioner, vitiates the assessment. The petitioner's counsel urged that denial of the opportunity to cross exa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es, its reiteration and regurgitation as it were on the grounds assailing the reassessment notice are precluded. The reliance on the decisions in the opinion of the Court is not appropriate because none of them disclose that the petitioner had approached the Court on an earlier occasion and were permitted to reiterate the same grounds at the completion of the assessment. As far as the validity of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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