Puja Vs PCIT (Punjab and Haryana High Court)
Mr. Vaibhav Gupta, Jr. Standing Counsel, accepts notice on behalf of respondent-Income Tax Department, and seeks time to file reply.
Prima facie, the impugned order dt. 03.04.2022, passed under Section 148 (A)(d) of the Income Tax Act, 1961 appears to have been passed with regard to a transaction which occurred in the financial year 2014-15 by serving a notice allegedly through E-filing portal on 21.03.2022, and giving a mere 07 days time to assessee to furnish a reply thereto. Prima facie, the time granted to the assessee to reply appears to be unreasonably short, and the assessee cannot be blamed for not being able to file the reply within such a short period. Therefore, prima facie this is a violation of principle of natural justice.
Pending further orders, there shall be stay of all further proceedings pursuant to Annexures P1 and P2.
List on 20.10.2022.
Reply be filed before the next date of hearing with copy in advance to counsel opposite.
