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TMI Blog2018 (3) TMI 527X X X X Extracts X X X X X X X X Extracts X X X X ..... be able to provide the relief to the petitioners which they seek before us if they are right in their contention. Issue gives rise to factual investigation. We have not examined the merits of the respective contentions. It would be open to the parties to urge their contentions before the CIT(A) who would decide the same in accordance with law. We are not entertaining this petition. However, bea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arch, 2017 issued by the Assessing Officer under Section 148 of the Income Tax Act, 1961 (the Act) seeking to reopen assessment for Assessment Year 2010-11. Pending consideration of this petition, the Assessing Officer has passed an order dated 29th December, 2017 under Section 143(3) r/w Section 147 of the Act relating to Assessment Year 2010-11. This led to amending the petition to also challeng ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... jurisdiction and entertain the petition. 3. It may be pointed out that Mr. Malhotra, learned Counsel appearing for the respondents has contested the issue of breach of natural justice. This would indicate that this issue requires factual determination, which can be best done by the Authorities under the Act. 4. There can be no dispute with regard to our jurisdiction to entertain the writ pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ies to urge their contentions before the CIT(A) who would decide the same in accordance with law. 5. In the above view, we are not entertaining this petition. However, bearing in mind the fact that the petition is pending before the impugned order dated 29th December, 2017 was passed, the time to file an appeal from the impugned order dated 29th December, 2017 is extended upto 12th March, 2018. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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