Allowing the petition, that on the facts and in view of the situation that during the relevant period there had been lock down restrictions due to the second wave of the covid-19 pandemic and subsequent to the extension given up to April 27, 2021, no further extension had been given to the assessee, the order passed under section 143(3) was to be set aside and the matter remanded to the Department for reconsideration after giving a final opportunity of two weeks time to the assessee to produce the necessary documents to substantiate the claim that the additional stock found during the survey did not belong to the assessee, but to its sister concern. On failure by the assessee to do so to the satisfaction of the Department, the Department could proceed further and pass orders afresh and in this context, no further grievance could be espoused by the assessee on the ground that opportunity had not been given. (AY.2011-12)