JUDGMENT

Manmohan, J. (Oral)

CM APPL.19469/2022 (exemption)

Exemption allowed, subject to all just exceptions.

Accordingly, the application stands disposed of.

W.P.(C) 6427/2022 & CM APPL. 19468/2022(stay)

1. Present writ petition has been filed challenging the Assessment Order dated 31st March, 2022, passed under Section 143 (3) read with Section 153A of the Income Tax Act, 1961 (hereinafter referred to as `the Act') for Assessment Year 2020-21.

2. Learned counsel for the petitioner states that the respondent No.1 while passing the said impugned order, made additions totalling to Rs.100,89,12,380/-primarily on the ground that the petitioner had failed to file reply to the show cause notice issued by the respondent No.1 on 22nd March, 2022 around midnight. He states that the said show cause notice was served upon the petitioner via e-mail asking the petitioner to respond to said notice by 3:45 pm on the very next day, i.e. 23rd March, 2022.

3. Learned counsel for the petitioner states that by way of the said show cause notice running into 92 pages, the petitioner was directed to provide various documents for the first time during the assessment proceedings. He states that the