TMI Blog2022 (6) TMI 1523X X X X Extracts X X X X X X X X Extracts X X X X ..... with shorter period to respond - giving a mere 7 days time to the Petitioner/assessee to furnish a reply to the said notice - HELD THAT:- The time granted to the Petitioner/assessee to submit reply to the said notice appears to be unreasonable short and the Petitioner/assessee cannot be blamed for not being able to file the reply within such a short period. Thus, it appears that there is a violat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order dated 4.4.2022 (Annexure P2) passed under Section 148A(d) of the Act and notice dated 5.4.2022 (Annexure P3) issued under Section 148 of the Act. 3. It is submitted by Learned Counsel appearing for the Petitioner that the Petitioner is a private limited company registered under the Companies Act involved in rendering services in various sectors of hospitality industry. The Petitioner was is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ch occurred in the financial year 2014-15 is unreasonable short and the assessee cannot be blamed for not being able to file reply within such a short period. There is a violation of the principle of natural justice. Learned Counsel further submits that if any inquiry is to be conducted with respect to the information which suggests that the income chargeable to tax has escaped assessment, the sam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed Counsel appearing for Respondents No.2 and 3 oppose the above arguments raised on behalf of the Petitioner. 5. I have heard Learned Counsel appearing for the parties and perused the above referred to documents/Annexures and other material available with due care. 6. From perusal of the documents/Annexures, it appears that the order dated 4.4.2022 (Annexure P2) passed under Section 148A(d) of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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