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2022 Supreme(Del) 1592

MANMOHAN, DINESH KUMAR SHARMA
Nidhi Agrawal – Appellant
Versus
Income Tax Officer, Ward 69(1) Delhi – Respondent


Advocates appeared:
Sandeep Kumar, Advocate, Shiven Khurana, Advocate, Ruchir Bhatia, Advocate

JUDGMENT

Manmohan, J. - Present writ petition has been filed challenging the reassessment notice dated 31st March, 2021 issued under Section 148 of the Income Tax act, 1961 ['the act'] for the assessment year 2016-17 as well as the assessment order dated 31st March, 2022.

2. Learned counsel for the petitioner states that even though the impugned notice was dated 31st March, 2021 and was issued vide email on 31st March, 2021 at 11:36 PM, yet it will be considered to have been issued/served to the petitioner on 01st april, 2021 and would thus be covered by the decision of this court in Mon Mohan Kohli vs. assistant Commissioner of Income Tax & anr., W.P.(C) No.6176/2021.

3. He further states that the notice dated 28th November, 2021 issued under section 143(2) read with Section 147 of the act, by which the respondents sought clarifications on issues mentioned in the annexure thereto was accompanied by a blank annexure making it impossible for the petitioner to respond to the same.

4. Learned counsel for the petitioner also states that the detailed objections raised by the petitioner vide reply dated 14th March, 2022 were not considered by the respondents while passing the impugned ass

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