9911796707
TMI Blog2022 (9) TMI 1392X X X X Extracts X X X X X X X X Extracts X X X X ..... to know that there had been deposits by the petitioner in cash in its bank accounts for the financial years relevant to the assessment years. On the basis of the above information, the Assessing Authority has arrived at the conclusion that there were reasons available for reopening of assessments, particularly in view of the fact that the petitioner had not filed statutory returns. Thus, on the premise that income chargeable to tax of the above amounts had escaped assessment, notices u/s 148 were issued to the petitioner. There was no response to the same - Evidently, in the absence of a statutory return and abject noncompliance with all notices, the Assessing Authority was not in a position to consider the claim of exemption or any o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to 2016-17 (assessment years in question), passed under Section 147 read with Section 144 read with Section 144B of the Income Tax Act, 1961 (in short 'Act'), all dated 28.03.2022. 3. At the outset, these Writ Petitions have been filed beyond the period of limitation prescribed under the provisions of the Act. This Court, thus, prima facie, finds that they are not maintainable. 4. That apart, the following constitutes the admitted position: (i) The petitioner has not filed returns of income for the assessment years in question. (ii) Based upon information received from Annual Information Report/Central Information Branch data, the Income Tax Department had come to know that there had been deposits by the petitioner in ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of incomes in response to notice under Section 148 of the Act. viii) Evidently, in the absence of a statutory return and abject noncompliance with all notices, the Assessing Authority was not in a position to consider the claim of exemption or any other issue for that matter. ix) Show cause notices dated 25.03.2022, 19.03.2022 and 23.03.2022 were issued to the petitioner, pursuant to the aforesaid letter dated 08.02.2022. Though served, the petitioner had not responded to the show cause notices as well. x) It is in the aforesaid circumstances that the impugned orders of assessment had come to be passed, challenged in these Writ Petitions. 5. Learned counsel for the petitioner submits that these Writ Petitions are filed more as m ..... X X X X Extracts X X X X X X X X Extracts X X X X
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