2025 (1) TMI 821

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..... . Heard learned counsel for the parties. 2. The challenge in this petition is to the impugned assessment order dated 20 March 2024. 3. In paragraph 49 of the petition, the petitioner has made a bald statement that no other alternate efficacious remedy is available to the petitioner save and except to file the present petition before the Court. This statement is mainly incorrect because against t .....

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..... It is not as if no time was granted to the petitioner. However, it is the petitioner's grievance that no adequate time was given. 6. Mr. Sharma, learned counsel for the respondent, has invited our attention to the adjournment request made digitally on 16 March 2024 by the petitioner's Chartered Accountant, who was handling the matter. In this, the Chartered Accountant stated that the assesse .....

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..... as not very candid with the Court. Besides, this is not a case of any patent breach of principles of natural justice. The petitioner does not allege the absence of any opportunity; rather, the petitioner's grievance concerns inadequate opportunity. 9. The issue of inadequate opportunity could always have been raised in an appeal against the assessment order. Even now, the petitioner is at liberty .....

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