9911796707
TMI Blog2022 (7) TMI 1161X X X X Extracts X X X X X X X X Extracts X X X X ..... have been made from the bank accounts held jointly by the assessee and her husband in one of bank accounts the first name is that of the petitioner-assessee. It is also alleged in the impugned order that, the source of deposit in all these bank accounts does not indicate whether such deposits has been made by her husband or by the assessee, out of their independent source of income . Consequently, the dispute involved in the present matters is essentially factual in nature. Moreover, appeals against the impugned assessment orders have already been filed under Section 246A by the Petitioner before the appropriate Authority. Consequently, this Court is of the view that it would be appropriate if the petitioner raises all her contentions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6,42,15,857/- for the assessment years 2016-17 and 2017-18 respectively were issued on 23rd March, 2022 at 23:59 hours and the Petitioner was given time up till 23:59 hours on 25th March, 2022 only i.e. less than forty eight hours to file replies to the Show cause notices. Consequently, according to him, the Petitioner was effectively denied her right to reply to the Show Cause notices. In support of his submissions, he relies on the decision of the Bombay High Court in Vodafone India Ltd. v. Union of India, (2013) 40 taxmann.com 545 (Bom.). 3. Learned counsel for the petitioner also states that the Petitioner did not come to know of the show cause notice, as she did not get the real time alert, as is mandatorily required under Secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the impugned order that, the source of deposit in all these bank accounts does not indicate whether such deposits has been made by her husband or by the assessee, out of their independent source of income . Consequently, the dispute involved in the present matters is essentially factual in nature. 6. Moreover, appeals against the impugned assessment orders have already been filed under Section 246A by the Petitioner before the appropriate Authority. Consequently, this Court is of the view that it would be appropriate if the petitioner raises all her contentions and submissions before the Appellate Authority. 7. Accordingly, the present writ petitions along with applications stand disposed of with liberty to the petitioner to raise ..... X X X X Extracts X X X X X X X X Extracts X X X X
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