9911796707
TMI Blog2024 (8) TMI 117X X X X Extracts X X X X X X X X Extracts X X X X ..... 22 and W. M. P. Nos. 2755, 2757 and 2761 of 2022 - - - Income Tax - Reopening of assessment u/s 147 - lack of opportunity to protest the proceedings - non providing hearing to assessee - petitioner submits that all subsequent communications were issued to an email address, which was not being used by the petitioner s accountant and, therefore, the petitioner did not receive the notices and could ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terference. For reasons set out above, the impugned re-assessment order and the demand notices issued pursuant thereto are quashed - Thus, matter is remanded for re-consideration. The petitioner is permitted to issue a response both in relation to the disposal of the petitioner s objections and to the show cause notice. Such consolidated response shall be submitted within (2) two weeks from the da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s were issued to an email address, which was not being used by the petitioner s accountant and, therefore, the petitioner did not receive the notices and could not reply thereto. Eventually, upon receipt of the show cause notice dated 22.10.2021, which was dispatched to the petitioner by post, it is stated that the present Writ Petition was filed. Learned counsel urges that the petitioner be provi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... petitioner replied to the notice issued under Section 148 of the Act on 23.01.2020. The petitioner also replied to the notice dated 15.04.2021 under Section 142 (1) of the Act. These notices were issued to the petitioner at the following e-mail address: [email protected]. The subsequent e-mails, including the e-mail issued on 21.04.2021, were issued to the following address: [email protected] ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... receipt of a copy of this order. For such purpose, the respondents are directed to enable the portal and provide access to the petitioner. Upon receipt of the petitioner s response, the assessing officer is directed to provide a reasonable opportunity, including a personal hearing, and thereafter, issue a fresh assessment order within (3) three months from the date of receipt of the petitioner s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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