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TMI Blog2023 (1) TMI 1269X X X X Extracts X X X X X X X X Extracts X X X X ..... es note of the fact that the notice issued under section 148 of Income Tax Act was served upon the Assessee and categorical findings has been recorded and the assessment order was passed. As there was no challenge to the findings recorded by the Assessing Authority, the Revisional Authority has not ventured into the arena and has dismissed the revision of the Assessee. The argument raised by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... elevant provisions and issuing notice and an assessment order was passed on 27.3.2015. The dispute is for the assessment year 2007-08. 3. Sri Suyash Agrawal, learned counsel appearing for the petitioner submitted that no notice under Section 148 of the Income Tax Act was issued to the Assessee. He further contended that against the assessment order, the Assessee had preferred revision under Sec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the attention of the Court to paras 3.4, 3.5 and 3.6 of the assessment order, which is extracted hereasunder : 3.4 Again, notice u/s 142(1) dated 23/02/2015 was issued fixing the date of hearing on 04/03/2015 but again no compliance. 3.5 Inspector of this office vide his report dated 10/03/2015 intimated that at present, assessee is posted as Customs Superintendent, at Nepalganj Road, Ba ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd requesting for another date which could not be allowed at this juncture when the case is to be barred by limitation on 31/03/2015. In fact to move application so late for fixing another date is merely a ploy to scuttle the assessment proceedings. Here, mention must be made that show cause notices u/s 144 giving assessee a final opportunity of being heard with proposal of addition had already be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isional Authority has not ventured into the arena and has dismissed the revision of the Assessee. The argument raised by the petitioner has no legs to stand as the findings recorded by the Assessing Authority was not put to challenge by the Assessee before any Forum. Raising of plea before this Court under Article 226 of the Constitution of India is not maintainable as the findings recorded by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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