A person who has not responded to any of the notices issued in the past cannot, without anything more, turn around and complain that in the last notice issued he was not granted reasonable time to respond.
This principle is stated in [2022] 440 ITR 602 (Ker) given the past conduct of the petitioner in not responding to six prior notices.
Further in this case the petitioner has omitted to reveal in the writ petition the receipt of notices or pleadings thereto which furthermore proved detrimental to its conduct.
https://dailytaxreporter.com/2022/03/23/taxpayer-should-mind-their-conduct-before-invoking-article-226-remedy/
