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TMI Blog2023 (2) TMI 318X X X X Extracts X X X X X X X X Extracts X X X X ..... 2.2022 was issued, without having regard to the reply, we are inclined to quash the impugned notices and order. There was, to our minds, clearly a failure to adhere to the directions contained in Clause N.1.3 of the Standard Operating Procedure (SOP) for Assessment Unit (AU) dated 03.08.2022; which required a minimum timeframe of seven days to be given to the noticee i.e., the petitioner. It is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6.2022; (ii) notice dated 09.12.2022; (iii) assessment order dated 19.12.2022; (iv) notice of demand dated 19.12.2022. 4. Issue notice. 4.1 Mr Abhishek Maratha, learned senior standing counsel, who appears on behalf of the respondents/revenue accepts notice. 5. In view of the directions that we propose to pass, Mr Maratha says that counter-affidavit need not be filed. 6 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 and 11.11.2022. The petitioner replied to these notices on 08.12.20222. 11. A perusal of the record shows that a show-cause notice was issued by the Assessing Officer (AO) on 09.12.2022, without taking into account the fact that the petitioner had filed a reply on 08.12.2022. Via the show-cause notice dated 09.12.2022, the petitioner was given time to respond by 13.12.2022, up until 11:30 hou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -mail of even date was forwarded from the following URL [email protected] to [email protected]. 13.1 It appears, that despite these e-mails having been escalated to the system [i.e., [email protected]] by the NaFAC team, the petitioner s grievance was not resolved. 13.2 We may note, that in this context, our attention has been drawn to the d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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