JUDGMENT

(Prayer: Writ Petition filed under Article 226 of the Constitution of India, to issue aWrit of Certiorarified Mandamus, to call for the records of the Respondent and annul the impugned order passed under Section 143(3) r.w.s 144B of the Act dated 21.04.2021 in PAN:AABCA1726F for the Assessment year 2018-19 in DIN No.ITBA/AST/S/143(3)/202-22/1032583822 (1) quash the same and direct the Respondent to pass fresh assessment order after affording opportunity to the Petitioner.)

1. The petitioner is a Limited Company and assails the impugned order of assessment dated 21.04.2021 for assessment year 2018-19. The challenge to the assessment is on the ground of violation of principles of natural justice.

2. The petitioner was in receipt of the show cause notice incorporating a draft assessment, which is dated 12.04.2021. The show cause notice/draft assessment order (DAO) granted time up to 14.04.2021 23.59 hours to either accept the proposal for modification or file a reply objecting to the same, and, if so required, seek an opportunity of personal hearing.

3. The petitioner responded immediately by reply dated 13.04.2021, asking for an extension of time on the ground that the interveni