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TMI Blog2019 (2) TMI 1626X X X X Extracts X X X X X X X X Extracts X X X X ..... he impugned orders. In the name of additional and extended opportunities, one cannot expect the authorities to prolong the matter in perpetuity. As rightly contended by the learned Standing Counsel, denial of opportunity differs from inadequate opportunity. Hear I reckon, even the latter contention cannot be urged. I, therefore, dismiss the writ petition. Nevertheless, I leave it open for the petitioner to approach the appellate authority if so advised. - WP(C).No. 4230 of 2019 - - - Dated:- 14-2-2019 - Mr. Dama Seshadri Naidu, J. Sri.T.M.Sreedharan (SR.) Smt.Divya Ravindran Sri.Ramesh Cherian John Sri.R.Bhaskara Krishnan Sri.V.P.Narayanan For The Appellant. Sri.Jose Joseph, For The Respondent. J ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng to him, denial of an opportunity differs from inadequate opportunity. Even if the petitioner's allegations were taken on the face value, they would only concern the merits. But, by no stretch, can this Court, according to Sri.Joseph, conclude there has been a denial of opportunity, much less any violation of principles of natural justice. 5. Heard Sri. T. M. Sridharan, the learned Senior Counsel, and Smt. Divya Ravindran, the learned counsel for the petitioner; and Sri.Jose Joseph, the learned Standing Counsel, for the respondents. 6. To begin with, on 06.12.2018 the assessing authority issued a show-cause notice about the transactions that took place during the financial year 2012-2013. Later, based on the notice ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vs. Agrl. Income Tax officer, 1989 (1 ) KLT 909 , has on facts observed: In the counter affidavit dated 4th august, 1987 filed on behalf of the respondents it is stated that a pre-assessment notice dated 1-2-1983 estimating the income was served on the assesse on 25-2-1983. the last date for filing reply to the proposals made in the pre-assessment notice was on 3-3-1983. Sri. M.J Udayavarma Raja, a sales tax practitioner, filed a petition date 7-3-1983 on behalf of the petitioner and that petition was received on 9-3-1983 after the assessment c2828ompleted on 3-31983. It is accordingly stated that the objections filed on 9-3-1983 could not be completed before the assessment orders were passed on 3-3-1983. the preassessment notic ..... X X X X Extracts X X X X X X X X Extracts X X X X
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