9911796707
TMI Blog2025 (4) TMI 1300X X X X Extracts X X X X X X X X Extracts X X X X ..... -4-2025 X X X X Extracts X X X X X X X X Extracts X X X X ..... s that even though this time was insufficient, the Petitioner, filed response on 30.03.2022 at 17.59 hours. However, the impugned Order was passed by the second Respondent at 17.22 hours of 30.03.2022. He, therefore, submits that this is a case where the Petitioner's response, even though filed within the time prescribed, was entirely ignored and the impugned re-assessment Order was made. Mr. Bhat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd without considering the reply filed by the assessee. The reasoning in the said decision will also apply to the facts of the present case. 7. Mr. Bhatt, states that no objection based on limitation would be raised provided the fresh re-assessment Order is made within three months of the uploading of this order. Besides, Mr. Bhatt states that the Petitioner will render full co-operation and not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The Petitioner was issued a Show Cause Notice and granted time to file a response by 23.59 hours of 30.03.2022. Such response was filed by the Petitioner at 17.59 hours on 30.03.2022. Even before the time limit indicated in the Show Cause Notice would expire, the second Respondent made the impugned re-assessment Order dated 30.03.2022 at 17.22 hours. Thus, the Petitioner's response filed within t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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