Case Law Details
AA 282, Kolappalur Primary Agricultural Coop Credit Society Limited Vs National Faceless Assessment Centre (Madras High Court)
Admittedly, as seen from the impugned assessment order several opportunities were given to the petitioner to respond to the notices sent by the respondents under Section 143 (2) as well as under Section 142 (1) of the Income Tax Act.
The petitioner also admits that the final show cause notice dated 09.08.2022 was also received by them. But, however, contends that even though they sought fifteen days time to submit a reply, within a period of three days, the impugned assessment order has been passed. In the impugned assessment order, it is observed that the petitioner acknowledged the show cause notice dated 09.08.2022 on 17.09.2022 and requested fifteen days time to furnish the details / documents. The respondents have also given reasons as to why further time cannot be granted as they observed that the cases were getting time barred on 30.09.2022 and therefore, the petitioner’s request for grant of time to furnish details cannot be considered by the respondents.
This Court does not find any infirmity in the reasons given by the respondents for rejecting the petitioner’s request for grant of further time to submit a reply and to furnish copies of the details / documents. Taking note of the fact that the petitioner has been provided with sufficient opportunities to respond to the notices sent by the respondents, as seen from the tabular column referred to supra, no further time can be granted to the petitioner to submit a reply as rightly held by the respondents under the impugned assessment order.
FULL TEXT OF THE JUDGMENT/ORDER OF MADRAS HIGH COURT
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