JUDGMENT

Manmohan, J. - Present writ petition has been filed challenging the assessment order dated 31st March, 2022 passed under Section 147 read with Section 144B of the Income Tax act, 1961 (for short ' the act') for the assessment Year 2016-17.

2. Learned counsel for the Petitioner states that the Petitioner was not given reasonable time to file reply to the show cause notice which was issued only on 30th March, 2022 at 16:21 p.m. effectively giving the Petitioner only eight hours' time to file reply to the show cause notice. He states that it was not possible to gather all the details of expenses incurred towards improvement of property, details of exemption claimed under Section 54 of the act and the authentic supporting documents/evidences, which had been referred to in the draft assessment order.

3. Learned counsel for the Petitioner contends that the time gap between giving the show cause notice and passing of the reassessment order was only around twenty two hours which means that the Respondents considered the reassessment proceedings as an empty formality.

4. Today, on instructions, Mr.Zoheb Hossain, learned standing counsel for the Revenue states that 'since the matter