JUDGMENT :

JOYMALYA BAGCHI, J.

1. Order dated 28.1.2019 passed by the 1st respondent refusing to permit the petitioner to file ‘F’ forms in respect of interstate transfer to his branch unit at Karnataka and consequentially reopen assessment proceedings on such score has been assailed in this writ petition.

2. Learned Counsel for petitioner submits that his business had closed down and he had left the place of business. Accordingly, he had no notice of the assessment proceedings including the assessment order dated 27.3.2015 passed therein by the 1st respondent in respect of assessment year 2011-2012 following the Best Judgment Method.

3. It is further contended only in 2018 upon recovery proceedings being initiated under the Revenue Recovery Act, the petitioner came to know of the aforesaid assessment order and thereafter made endeavours to collect the ‘C’ forms and ‘F’ declaration forms from the branch office and on 14.1.2019 made a representation to the 1st respondent seeking permission to submit 12 ‘F’ forms with regard to interstate transfer and to reopen the assessment proceedings and give exemption by taking into account the aforesaid ‘F’ declaration forms.

4. He relied on decisio