HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 4811 of 2025 Court No. - 3 HON'BLE SHEKHAR B. SARAF, J. HON'BLE PRAVEEN KUMAR GIRI, J. 1. Heard learned counsel for the parties. 2. In the present writ petition, the writ petitioner is aggrieved by an assessment order and a penalty order passed in the year 2023. 3. The contention of the petitioner is that he was not aware of the said proceedings. However, Sri Naveen Chandra Gupta, learned counsel appearing on behalf of Income Tax Department, has indicated the documents, including paragraphs in the impugned penalty notice and the assessment order, which indicate that service of notice was made on several occasions upon the petitioner. 4. In light of the above, we are of the view that the writ court should not intervene after the period of two years having been passed. 5. However, for the ends of justice, we dispose of the writ petition with a direction to the petitioner to file an appeal under section 246-A of the Income Tax Act, 1961, alongwith an application for condonation of delay in filing of the said Versus Counsel for Petitioner(s) : Kamlesh Kumar Yadav, Vijay Kumar Srivastava Counsel for Respondent(s) : A.S.G.I., Ankur Agarwal Surendra Bahadur Chaturvedi .....Petitioner(s) Union Of India And Another .....Respondent(s) appeal. The petitioner may also file an application for stay, in accordance with law. If such applications are filed within a period of four weeks from date, the authority concerned is directed to consider the matter in a sympathetic manner and pass necessary orders, in accordance with law. September 23, 2025 K.K. Maurya WTAX No. 4811 of 2025 2 (Praveen Kumar Giri,J.) (Shekhar B. Saraf,J.) Digitally signed by :- KAMLESH KUMAR MAURYA High Court of Judicature at Allahabad