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TMI Blog2021 (11) TMI 1135X X X X Extracts X X X X X X X X Extracts X X X X ..... - HELD THAT:- A narration of the facts, would clearly go to indicate that the impugned assessment order has been made in contravention to the basic principles of natural justice and fair play, inasmuch as the petitioner was not granted an opportunity to file its reply on the proposed additions and a further opportunity of being heard in the matter. Once that be so, obviously, impugned order ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ggrieved by the assessment order made on 8.4.2021 and a consequential notice of demand, issued under Section 156 of the Income Tax Act,(for short, the Act ) alongwith notice issued for initiating the penalty proceedings in the assessment year 2018-19, the petitioner has filed the instant petition for granting the following substantive relief: Issue appropriate writ, order or direction, quashi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... otices issued by the respondents, under Section 142(I) of the Act by filing its elaborate replies dated 13.10.2019, 01.02.2021 and 01.03.2021. Upon the receipt of the above said replies, the respondent passed an assessment order, intimating the proposed additions to the petitioner on 26.3.2021, of Rs. 5,18,20,934/-. The said draft Assessment Order was accompanied by a show cause notice eliciting a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to file its reply on the proposed additions and a further opportunity of being heard in the matter. 7. Once that be so, obviously, impugned order cannot be sustained. In taking this view, we are duly supported by the judgments rendered by a Division Bench of the Delhi High Court in WP(c) No. 5250 of 2021, titled as Deep Gard versus Union of India, decided on 3.6.2021 and the Division Bench of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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