TMI Blog2022 (4) TMI 1085X X X X Extracts X X X X X X X X Extracts X X X X ..... w cause notice-cum-draft assessment order was only placed on the portal but was not intimated to the petitioner - HELD THAT:- This Court is of the view that the impugned show cause notice-cum-draft assessment order has been issued within limitation as the same was admittedly dispatched on 31 st March, 2022 at 11.36 PM. Consequently, the petitioner is not entitled to benefit of judgement of this Co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch, 2022 in accordance with law, at the first instance. In the event, respondent no.2/NFAC does not find any merit in the objections filed by the petitioner, then it shall proceed further in the matter in accordance with law and pass appropriate orders. X X X X Extracts X X X X X X X X Extracts X X X X ..... s that the notice dated 28th November, 2021 issued under section 143(2) read with Section 147 of the Act, by which the respondents sought clarifications on issues mentioned in the annexure thereto was accompanied by a blank annexure making it impossible for the petitioner to respond to the same. 4. Learned counsel for the petitioner also states that the detailed objections raised by the petitione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... only at the fag-end. 7. Having heard learned counsel for the parties, this Court is of the view that the impugned show cause notice-cum-draft assessment order has been issued within limitation as the same was admittedly dispatched on 31st March, 2022 at 11.36 PM. Consequently, the petitioner is not entitled to benefit of judgement of this Court in Mon Mohan Kohli (supra). 8. However, this Court ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... respondent no.2/NFAC does not find any merit in the objections filed by the petitioner, then it shall proceed further in the matter in accordance with law and pass appropriate orders. 10. With the aforesaid directions, present writ petition along with pending applications stand disposed of. This Court clarifies that it has not commented on the merit of the controversy. The rights and contentions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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