9911796707
TMI Blog2023 (10) TMI 1462X X X X Extracts X X X X X X X X Extracts X X X X ..... ha Halbe for the Petitioner Mr. Suresh Kumar for the Respondents-Revenue PC:- 1. Petitioner is impugning an assessment order dated 26th March 2022 passed under Section 147 read with Section 144 read with Section 144B of the Income Tax Act, 1961 ("the Act") on the principal ground that no notice was issued prior to passing the assessment order. It is Petitioner's case that notice was not sent e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itioner. If email id was not available in the portal, it should have been served physically upon Petitioner at least by courier or speed post and acknowledgment filed. There have been SOPs in place and the last one which is in force before the assessment order was passed is dated 23rd November 2020. After the assessment order was passed, a fresh/revised SOP has been released on 3rd August 2022 for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... number on which SMS is sent along with the date and time of sending, will be updated in the database accessible to AU on Insight; G.3.3 To ensure completeness of record, the AU shall enter all the details referred in Para G.3.2 above, along with the date of delivery, if any, of the Speed Post letter in the Case History." 3. We would direct Respondents to strictly comply with the SOP dated 3r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er, notice whereof shall be communicated at least five working days in advance. The proceedings to be completed by 31st January 2024. 7. In view of the above, the consequential demand notice under Section 156 of the Act and penalty show cause notice under Sections 271 and 271F of the Act, both dated 26th March 2022, are also quashed and set aside. 8. Petition disposed. 9. We clarify that we hav ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
