TMI Blog2022 (5) TMI 526X X X X Extracts X X X X X X X X Extracts X X X X ..... cording to the petitioner's counsel, the same has not been served on him and that notice as well as the subsequent assessment order since has been uploaded in the website, which the petitioner was able to retrieve only on 22.03.2022, the petitioner's counsel contended that, there was no chance for the petitioner to reply to the show cause notice. Therefore, if one chance is given to him, c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oner since has not filed the return, the Revenue wanted to process it under Section 147 of the Act. Therefore, a notice under Section 148 of the Income Tax Act 1961 (In short 'the Act') was issued on 02.02.2022, which the petitioner admittedly received on 04.02.2022. 2. Thereafter, according to the petitioner, no notice had been served on him except the impugned order of assessment date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... und. Accordingly, the learned Standing Counsel for the Revenue seeks the dismissal of the writ petition. 4. I have considered the submissions made by the learned counsel on either side and have perused the materials placed on record. 5. Insofar as the show cause notice issued by the Revenue dated 03.03.2022 is concerned, according to the petitioner's counsel, the same has not been served ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .03.2022 is set aside and the matter is remitted back to the respondents for reconsideration. While reconsidering the matter, it is open to the assessee to treat the show cause notice dated 03.03.2022 as the fresh show cause notice, as the same would not be again issued by the Revenue and respond to the same, by giving documents and inputs / reply within two weeks from the date of receipt of a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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