On writ the  fact remained that the assessee endeavoured to submit a reply on December 3, 2022 but could not do so because the portal was not accessible by that time. As a result, the assessee was unable to place on record submissions to support the contention that the income from sale of property was only liable to capital gains and that it should not be treated as business income. For that reason, the order had to be quashed. The matter was remanded for reconsideration subject to payment of Rs. 10,000 as costs by the assessee to the Adyar Cancer Institute, Chennai.(SJ) (AY.2021-22)