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TMI Blog2023 (7) TMI 1550X X X X Extracts X X X X X X X X Extracts X X X X ..... xpiring limitation period - HELD THAT:- Whether there is any CBDT provision in Income Tax Act, 1961 or the rules having empowered the CBDT to issue a directive on dispensation of requirement to give show cause notice on earlier omission by assessee in the proceeding. Nothing could be shown. It transpires that revenue was mandated to give the show cause notice and on having given it was bound by d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Mohapatra, Advocate (Senior Standing Counsel, I.T.) ORDER 1. Mr. Ray, learned senior advocate appears on behalf of petitioner (assessee) and demonstrates, the show cause notice was issued on 12th December, 2022 requiring reply by late afternoon of 16th December, 2022. This was contrary to direction by Central Board Direct Taxes (CBDT) for there being minimum seven days notice, unless to be cur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wanted to. Further, as mentioned in clause no. N.1.3.2 Response time of 7 days may be curtailed, keeping in view the limitation date for completing the assessment. Hence, technically there is no violation of the SOP issued by the CBDT on this behalf." 3. Mr. Ray disputes alleged omission can be fatal to contention of his client. 4. We made query from Court on whether there is any CBDT provision ..... X X X X Extracts X X X X X X X X Extracts X X X X
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