JUDGMENT

Manmohan, J. - Present writ petition has been filed challenging the assessment order, notice of demand as well as penalty notice under Section 271AAC all dated 25th March, 2021.

2. Mr. Ved Jain, learned counsel for the petitioner states that vide show cause notice dated 18th March, 2021, the petitioner was called upon to respond to the draft assessment order till 23:59 hours on 26th March, 2021. He states that prior to the date stipulated in the show cause notice, the impugned assessment order was passed on 25th March, 2021. He also states that on the very same day, the notice of demand as well as penalty notice was issued to the petitioner.

3. Mr. Kunal Sharma, learned counsel for the respondents prays for some further time to file a counter affidavit and obtain instructions.

4. However, we find that the notice in the present writ petition had been issued on 29th April, 2021 and the matter was adjourned to 21st May, 2021. On 21st May, 2021, Mr. Sharma had been given further time to file a counter affidavit and the interim stay granted by this Court was made absolute. However, till date, no counter affidavit has been filed.

5. This Court is of the view that the respondents hav