(1.) PETITIONER is an assesse on the rolls of the 2nd respondent. Ext.P1 is an order of assessment passed against the petitioner for the assessment year 2007-08. Seeking revision of the said order petitioner filed Ext.P2 invoking the powers of the 3rd respondent under Section 264 of the Income Tax Act. Various grounds have been urged in Ext.P2. When notice of hearing was issued an authorized representative of the petitioner appeared before the 3rd respondent. Thereafter the 3rd respondent passed Ext.P3 order rejecting Ext.P2 application. It is challenging Ext.P3 order that this writ petition has been filed,.
(2.) I heard the counsel appearing for the petitioner and also the Standing counsel appearing for the respondents. The main contention raised by the counsel for the petitioner is that Ext.P3 is illegal in so far as none of the contentions raised either in Ext.P2 or during the personal hearing, were considered by the 3rd respondent while issuing the said order.