Dismissing the petition, the Court held that on the facts, there was no violation of principles of natural justice. In respect of the first show-cause notice the assessee had asked for time up to May 20, 2023 and it was granted to him. The assessee did not file reply and therefore, the authority was well within its power not to grant further time. Though the second show-cause notice was issued, the assessee asked for time and did not file a reply. The assessee could not go on asking for time in response to the show-cause notice issued one after another. Therefore, there was no ground to interfere. The assessee could avail of the remedy of filing an appeal before the Commissioner (Appeals) under section 246A against the assessment order. Since the writ petition had remained pending, the Commissioner (Appeals) was to examine the appeal on the merits and the stay application, if any, filed along with the appeal, without getting into the question of limitation. (AY. 2016-17)