Reassessment notices challenged for CBDT circular non-compliance were not entertained because the petitioner delayed and participated in proceedings.

Reassessment notices under section 148 were challenged for alleged non-compliance with CBDT circular requirements, but the petitioner had not promptly approached the Court and had participated in the subsequent proceedings. Notices under section 143(2) and section 142(1) were issued, and the materials relied upon were disclosed to the petitioner. In these circumstances, the Court declined to interfere, treating the writ as delayed and refusing to entertain the challenge to the reassessment notices.

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Issues: Challenge to the reassessment notices issued under section 148 of the Income-tax Act, 1961 on the ground of non-compliance with the CBDT circular requirements and whether the writ petition should be entertained despite the petitioner's participation in the subsequent proceedings and the delay in approaching the Court.

Analysis: The notices under section 148 were issued on 25.03.2023 and 26.03.2023. The petitioner did not promptly challenge them and participated in the proceedings thereafter. Further notices under section 143(2) and section 142(1) were issued, and the materials relied upon were disclosed to the petitioner. In these circumstances, the Court found that the petition suffered from delay in approaching the Court and declined to interfere.

Conclusion: The challenge to the notices was not entertained and the writ petition was dismissed.

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