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TMI Blog2019 (1) TMI 1219X X X X Extracts X X X X X X X X Extracts X X X X ..... tain proposals for revision of the assessment. Needless to state that the petitioner can raise all his objection before the 2nd respondent by way of filing a reply to the notice of proposal - Without doing so, the petitioner has filed the present writ petition by challenging the proceedings at the notice stage itself. This Court is, thus, not inclined to entertain the writ petition, at this stage, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itioner that the 1st respondent, having issued a notice dated 05.01.2016 and when the petitioner has made the payment of tax as determined by the 1st respondent, the 2nd respondent is not having jurisdiction to frame an assessment. 4. Admittedly, the 1st respondent is an Enforcement official, whereas the 2nd respondent is the Assessing Authority. Now, the impugned notice is issued by the 2nd re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , being the quasi judicial authority is bound to consider the issue on merits and in accordance with law uninfluenced by any of the directions, if any, issued by the higher officials or the report filed by Enforcement officials. 6. Therefore, without expressing any view on the merits of the matter, this Writ Petition is disposed of by directing the petitioner to give reply to the notice of prop ..... X X X X Extracts X X X X X X X X Extracts X X X X
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