9911796707
TMI Blog2024 (1) TMI 1190X X X X Extracts X X X X X X X X Extracts X X X X ..... the notice under Section 148A(b) of the Act - HELD THAT:- Petitioner was not provided an opportunity of hearing and the matter may be remanded back to the respondent-AO so as to enable the petitioner to file a reply to the notice u/s 148A(b) because keeping this matter pending before Hon ble Court would delay the assessment proceedings, if required to be re-opened after considering the reply of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned Senior Standing Counsel Mr. Varun K. Patel with learned advocate Mr. Dev D. Patel for the respondent. 2. By this petition under Article 226 of the Constitution of India, the petitioner has prayed for the following reliefs : (a) quash and set aside the impugned notices and order at Annexure-'A1, A2 and A3' to this Petition; (b) pending the admission, hearing and final disp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 148A(b) of the Act on 10.03.2022 for Assessment Year 2018-19 along with the details of the information on the basis of which the respondent believed that the income chargeable to tax has escaped assessment. 3.3. The notice dated 10.03.2022 mandated on seven days time to file reply. The time was sought on behalf of the petitioner for fifteen days on 12.03.2022. However, the respondent passed t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing Counsel Mr. Varun Patel for the respondent fairly stated that the petitioner was not provided an opportunity of hearing and the matter may be remanded back to the respondent-Assessing Officer so as to enable the petitioner to file a reply to the notice under Section 148A(b) of the Act because keeping this matter pending before Hon ble Court would delay the assessment proceedings, if required t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and but not exceeding thirty days from the date on which such notice is issued, or such time, as may be extended by him on the basis of an application in this behalf, as to why a notice under section 148 should not be issued on the basis of information which suggests that income chargeable to tax has escaped assessment in his case for the relevant assessment year and results of enquiry conducted, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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