9911796707
TMI Blog2022 (3) TMI 1547X X X X Extracts X X X X X X X X Extracts X X X X ..... ome Tax - Reopening of assessment u/s 147 - time granted to the petitioner to reply was not made fully available to the petitioner - HELD THAT:- Show Cause Notices were issued as to why the proposed variations should not be made, where, the Revenue directed the assessee to submit their response through the registered e-filing account at www.incometax.gov.in by 23:59 hours of 28.03.2022. In r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he time granted to the petitioner to reply was not made fully available to the petitioner to utilize and in fact even before the closing time of filing the reply, the very impugned assessment orders were passed. On that ground itself, it can easily be construed that the principles of natural justice has been violated. Therefore, on that ground, this Court is inclined to set aside these orders and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tices under Section 148 of the Act were issued, followed by the further procedure to be adopted by both the assessee as well as the Revenue and ultimately on 27.03.2022, Show Cause Notices were issued as to why the proposed variations should not be made, where, the Revenue directed the assessee to submit their response through the registered e-filing account at www.incometax.gov.in by 23:59 hours ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... In respect of W.P.No.7929 of 2022, the web portal was closed by 18:50 hours on 28.03.2022 itself and the assessment order though passed on 28.03.2022, it has been signed on the next day i.e., on 29.03.2022 at 07:14 hrs IST. 6. Thus, the evidences would show clearly that the time granted to the petitioner to reply was not made fully available to the petitioner to utilize and in fact even before ..... X X X X Extracts X X X X X X X X Extracts X X X X
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