MICONI HEMAL SHAH Vs. ADDITIONAL/ JOINT/DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX/INCOME TAX OFFICER

JUDGEMENT

(1.) By this petition under Article 227 of the Constitution of India, the petitioner has prayed for quashing and setting aside the assessment order dtd. 29/3/2022 on the ground that the petitioner was not given adequate opportunity of hearing by the respondent-Assessing Officer.

(2.) Brief facts of the case are that the petitioner filed return of income for the Assessment Year 2017-2018 on 20/2/2018 at Rs.23,080.00. Thereafter, notice under sec. 148 of the Income Tax Act, 1961 [for short 'the Act'] was issued by respondent No.2 on 31/3/2021 for seeking to re-assess the income of the petitioner. The petitioner filed return of income pursuant to the notice under sec. 148 of the Act on 27/4/2021. The respondent provided reasons recorded for reopening on 29/6/2021.

(3.) Thereafter, the E-assessment was carried out and notice dtd. 12/7/2021 was issued followed by notice dtd. 10/12/2021 under sec. 142(1) of the Act which was replied by the petitioner on 24/12/2021.