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2024 (6) TMI 1297

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..... order passed ignoring request to extension of time to reply to SCN - proposal for adding all credits in the bank statement - HELD THAT:- On perusal of show cause notice it is evident that such notice deals with aggregate credit entries in the petitioner's bank statement and the proposal to treat this aggregate sum as unexplained money u/s 69A r/w 115BBE of the Income Tax Act. On perusal of ea .....

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..... lkumar Ramamoorthy For the Petitioner : Mr. A.S. Sriraman For the Respondents : Mrs. S. Premalatha, Junior Standing Counsel ORDER An assessment order dated 23.03.2023 pertaining to assessment year 2018-2019 is the subject of challenge in this writ petition. 2. In respect of the above mentioned assessment year, reassessment proceedings were initiated against the petitioner. After issuing notices un .....

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..... e petitioner was made for the first time in show cause notice dated 13.03.2024. He further submitted that the time provided for responding thereto was insufficient. He also pointed out that the communication dated 20.03.2024 adjourning the case to 21.03.2024 was digitally signed after 11.00 p.m. on 20.03.2024. Therefore, he makes a request that the petitioner be provided an opportunity to respond .....

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..... otices under Sections 143(2) and 142(1), this issue was not raised in such notices. In these circumstances, it was necessary to provide a reasonable time to the petitioner to respond to the show cause notice. The show cause notice granted three days originally and this time limit was extended by a further three days. Since sufficient time was not given to the petitioner to respond meaningfully to .....

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