9911796707
TMI Blog2024 (12) TMI 714X X X X Extracts X X X X X X X X Extracts X X X X ..... equest for additional time to respond to SCN due to Covid-19 situation - HELD THAT:- The petitioner has placed materials to show that it responded to Ext.P11 notice by filing its response on 20.4.2021 itself (Ext.P13). The screenshot of the e-filing proceedings would show that the competent authority has duly received the response. The e-proceedings response acknowledgment shows the receipt of the response with the date 20.04.2021, as evidenced by Acknowledgment. The respondents passed Ext.P16 assessment order on 20.4.2021 confirming the draft assessment order on the ground that no reply has been filed by the assessee to the show cause notice dated 10.4.2021. As petitioner has produced relevant materials to show that it had submitted the re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oner responded to the same by filing its reply dated 4.3.2021 (Ext.P10). While so, Section 144B came into effect on 1.4.2021. The petitioner received a second show cause notice dated 10.4.2021 with a fresh draft assessment order calling upon it to show cause as to why the assessment should not be completed as per the draft assessment order (Ext.P11). In the show cause notice it was directed that response shall be filed on or before the midnight of 15.4.2021. At that point of time, the staff of the petitioner who attended to assessment proceedings and responding to the various notices were quarantined due to Covid-19. The petitioner received Ext.P11 notice only on 12.4.2021. 14.4.2021 was a bank holiday. Therefore, the petitioner was constra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .P11 obtained from the relevant website in support of his contention. Ext.P12 shows that the petitioner has requested for time to respond to Ext.P11 on medical grounds and agreed to respond to the notice by 20.4.2021. The petitioner has placed materials to show that it responded to Ext.P11 notice by filing its response on 20.4.2021 itself (Ext.P13). The screenshot of the e-filing proceedings would show that the competent authority has duly received the response. The e-proceedings response acknowledgment shows the receipt of the response with the date 20.04.2021, as evidenced by Acknowledgment No.20042114694737 (Ext.P15). The respondents passed Ext.P16 assessment order on 20.4.2021 confirming the draft assessment order on the ground that no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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