ORDER :

(BHARGAV D. KARIA, J.)

1. Heard learned Senior Advocate Mr.Tushar Hemani with learned advocate Ms.Vaibhavi K. Parikh for the petitioner and learned Senior Standing Counsel Mr.Varun K. Patel with learned advocate Mr.Dev D. Patel for the respondent.

2. This petition is filed challenging the Assessment Order dated 31^st March, 2022 passed by the respondent under Section 147 read with Section 144B of the Income Tax Act, 1961 (for short ‘the Act’) as well as the demand notice of even date issued under Section 156 of the Act for Assessment Year 2016-17 on the ground of breach of principles of natural justice as the show-cause notice for proposed addition was issued on 29^th March, 2022 and the petitioner was asked to file reply on the same day before 23.59 hours which was humanly impossible.

3. The brief facts of the case are as under :

3.1. During the year under consideration, the petitioner was engaged in the business of trading in ornaments and bullions. The petitioner filed return of income on 18.09.2016 declaring total income at Rs.4,65,170/-.

3.2. The case of the petitioner was reopened by issuance of notice dated 31.03.2021 under Section 148 of the Act.

3.3. The petitioner, vide le