Reopening of assessment notice challenged for prior scrutiny, four-year limit, and disclosed material; ad-interim stay granted.

A writ petition challenged reopening of assessment under Section 148 for AY 2012-13 on the grounds that the assessment had already been completed under Section 143(3), the notice was issued beyond four years, and the reopening material had already been disclosed and considered in the original assessment. The court directed notice to the respondent, kept the petition pending for further hearing, and granted ad-interim stay against the impugned notice pending the returnable date.

---

---

Issues: Challenge to a notice reopening assessment under Section 148 of the Income-tax Act, 1961 for Assessment Year 2012-13, and request for interim protection pending the returnable date.

Analysis: The petition assailed the reopening notice on the ground that the assessment had already been completed under Section 143(3) of the Income-tax Act, 1961, the notice had been issued beyond four years, and the material forming the basis of the reopening was already disclosed and considered during the original assessment. As the respondent did not appear, notice was directed to be issued and the petition was kept pending for further hearing.

Outcome: Ad-interim stay was granted against the impugned notice, and the matter was made returnable on a later date.

---