Anuradha Doshi Vs ITO (Delhi High Court)
The petitioner, an NRI residing in Abu Dhabi since 2006, challenged an assessment order dated 31.03.2022 passed under Section 147 read with Section 144 of the Income Tax Act, along with consequential demand notices, penalty orders, recovery proceedings, and a bank account attachment order dated 12.01.2026. The petitioner stated that she became aware of the assessment and bank attachment only on 27.01.2026 when she attempted to operate her bank account in Mumbai. Thereafter, she accessed the Income Tax Business Application (ITBA) portal and obtained a copy of the assessment order.
The petitioner argued that the assessment order had been passed in violation of the principles of natural justice because no notice had been served upon her. It was contended that the notices were sent to an Inderpuri, New Delhi address where she had lived about twenty years earlier. The petitioner also argued that the Assessing Officer could have obtained her current address from the bank.
The Revenue contended that the notices were sent to the address available in the petitioner’s PAN records and passport. It was submitted that the petitioner had not updated her details or filed the necessary information after dealing with property in India. The Revenue further argued that the Assessing Officer could not be expected to obtain the address from the bank, particularly when bank details were not available with the Department.
