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TMI Blog2022 (6) TMI 1523X X X X Extracts X X X X X X X X Extracts X X X X ..... Singh Chandel For Petitioner : Shri Siddharth Dubey, Advocate For Respondent No.1 : Shri Sumit Singh, Advocate For Respondents No.2&3 : Shri Ajay Kumrani, Advocate on behalf of Shri Amit Chaudhary, Advocate Order on Board 1. With the consent of Learned Counsel appearing for the parties, the matter is heard finally. 2. The instant petition has been preferred by the Petitioner being aggri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the Petitioner to file its reply. The Petitioner was unable to file reply to the notice as the transaction in question related to the financial year 2014-15 and the time was short. Thereafter, order dated 4.4.2022 (Annexure P2) was passed under Section 148A(d) of the Act and a notice was issued under Section 148 of the Act initiating re-assessment proceeding on 5.4.2022 (Annexure P3). Learned C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Act before issuance/passing of the notice/order under Section 148A(b), Section 148A(d) and Section 148 of the Act in the present case, but the same has not been done. Therefore, it is prayed by the Learned Counsel that the order dated 4.4.2022 (Annexure P2) and the notice dated 5.4.2022 (Annexure P3) be quashed and the Respondents be directed to afford proper opportunity of hearing to the Petit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 violation of principle of natural justice. Therefore, the prayer made on behalf of the Petitioner/assessee appears to be reasonable. Thus, the order dated 4.4.2022 (Ann ..... X X X X Extracts X X X X X X X X Extracts X X X X
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