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Dear Sir,
With reference to your notice No. 100000137142640 dated 7-12-2022 requiring it provide the
relevant record for the captioned tax year.
We take the opportunity to explain that the required documents in under process.
Therefore, unable to present the case before your good self. It would be injustice if proper
time would not be provided to taxpayer. Reliance placed on 2012PTD964 (High Court):
Assesse had been provided five days time through each such notice to respond
thereto—According to C.B.R Circular No.7(2), dated 01-02-1994, assesse was required
to be provided 15 clear days for giving his explanation – Ample opportunity had not
been provided to assessee to explain his position through reply to such notices, thus
he could not be penalized for default on part of Assessing Authority – Assessing
Authority had no valid reason to amend completed assessment –Tribunal set aside
impugned order for being violative of such Circular --
Keeping in view the above submission, it’s to be requested that at least minimum 15 days to
be granted and the case may be fixed for other suitable date, which is convenient to your
good self preferably on or after 04-03-2023.
Thanking You,
FARHAN SHAHZAD
Advocate High Court