26,79,656/- The petitioner filed a rectification request under section 154 of the Income Tax Act, on 11-01-2019 for rectification of the order dated 06-08-2018. The said rectification request was rejected on 14-05-2019 and no benefit was given of TDS already deducted of more than Rs. 16 Lac, which was with the department. A show cause notice was issued under section 140 A(3) to the petitioner on 06-02-2020 for non payment of Tax of more than Rs. 11 Lac for the assessment year 2017-2018. The petitioner submitted his reply on 18-02-2020 requesting the Assessing Authority to consider the Form 16 and Form 26 AS for the assessment year 2017-2018 and to correct the demand raised by the department accordingly. However, such request/reply to the show cause notice was not considered and again a letter was issued for payment of outstanding dues on 15-092021. This notice was issued during the period of Covid Pandemic and the petitioner, being a NonResident Indian Seafarer, was on board the outgoing ship and for this reason, he could not reply to the show cause notice within time. On 0606-2023, a show cause notice under section 22(1) of the Income Tax Act was issued by the respondent no. 2 to show cause as to why the penalty be not be levied on the petitioner. The petitioner submitted his reply on 20-07-2023 and he again made a request to consider the fact that TDS has already been deducted on the gross total income of Rs. 60,09,769/- The petitioner filed a revision under section 264 of the Income Tax Act before the respondent no. 2 in the meantime on 11-07-2023. He was later on advised to file an application for condonation of delay and he filed an application for condonation of delay on 01-032024. Both the application for condonation of delay and the application for revision were before the respondent no. 2 at the time of passing of the order impugned dated 18-03-2024, but, they were decided separately by the orders impugned. Now, the respondents are pressing the demand for Rs. 11,34,816/-
