9911796707
TMI Blog2024 (11) TMI 245X X X X Extracts X X X X X X X X Extracts X X X X ..... sing Officer - denial of principle of natural justice - HELD THAT:- As in the impugned assessment order respondent-Assessing Officer has not even referred to the replies dated 23.03.2022 and 25.03.2022 filed by the petitioner nor he has referred to the show-cause notice dated 27.03.2022 issued by him along with draft assessment order. Thus, we are of the opinion that the impugned order dated 29.03 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e respondent-Assessing Officer. 2. Brief facts of the case are that the petitioner filed return of income for the Assessment Year 2017-2018 on 20.02.2018 at Rs. 23,080/-. Thereafter, notice under section 148 of the Income Tax Act, 1961 [for short the Act ] was issued by respondent No.2 on 31.03.2021 for seeking to re-assess the income of the petitioner. The petitioner filed return of income pursua ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 03.2022. 6. Learned advocate Mr. B.S. Soparkar for the petitioner submitted that as the petitioner is not provided the opportunity of hearing to file reply to the show-cause notice dated 27.03.2022 as per the provisions of section 144B of the Act and time of only 24 Hours was given for filing the reply and as such, the petitioner could not file the reply within the time provided by the respondent- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated 23.03.2022 and 25.03.2022 filed by the petitioner nor he has referred to the show-cause notice dated 27.03.2022 issued by him along with draft assessment order. 9. In view of the above facts, we are of the opinion that the impugned order dated 29.03.2022 of not providing opportunity of hearing results into breach of principle of natural justice. The impugned order dated 29.03.2022 is accordin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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