(1.) Where the petitioner-assessee was confronted with draft assessment order under Sec. 144B of the Income Tax Act , 1961, and wanted to submit his response to such assessment order, whether in the facts of the case the Department was justified in not granting time to file reply especially when, the seeking of time by the assessee was during the pandemic period-is the question posed.
(2.) With request and consent of learned advocates for the parties, the petition was taken up for final consideration today.
(3.) Petitioner has prayed to set aside assessment order dtd. 27/5/2021 passed under Sec. 143(3) read with Sec. 144B of the Income Tax Act, 1961 (hereinafter mentioned as "the Act"). The petitioner has also challenged the notice of demand dtd. 27/5/2021 as well as notice regarding penalty under Sec. 274 read with Sec. 270A of even date, which all related to the Assessment Year 2018-19.