TMI Blog2023 (6) TMI 824X X X X Extracts X X X X X X X X Extracts X X X X ..... mpugned order dated 29/07/2022 till today will stand excluded or in any case; the timeline will stand proportionately extended. We clarify that we have not examined the merits of the matter because the same has to be examined by the AO. Needless to add, all contentions of all parties, including the defences available to the Assessee u/s 149 of the Income Tax Act and all rights and contentions t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g for the parties. Even otherwise, by order dated 20/02/2023, the Court had clarified that an endeavour would be made to dispose of this petition finally at the admission stage. 3. The petitioner was served a notice dated 20/05/2022 under Section 148 A(b) of the Income Tax Act requiring the petitioner to show cause within two weeks why notice under Section 148 of the Income Tax Act should not b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from paragraphs 3 and 4 of the order dated 29/07/2022. 6. Thus, the order dated 29/07/2022 was made without considering the objections filed by the petitioner on 31/05/2022. Instead of going into the issue of whether the objections should have been filed in the physical form or through e-mail, we think that in the peculiar facts of the present case, the interest of justice would be met if the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from the date of the impugned order dated 29/07/2022 till today will stand excluded or in any case; the timeline will stand proportionately extended. 9. Further, we clarify that we have not examined the merits of the matter because the same has to be examined by the Assessing Officer. Needless to add, all contentions of all parties, including the defences available to the Assessee under Sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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