Reassessment notice challenge for noncompliance with E-verification scheme and issuance procedure under the Income-tax framework.

A challenge was raised to a reassessment notice under section 148 on the ground that the Scheme under section 135A, including preliminary E-verification, had not been followed and that the notice sequence was contrary to section 151A. The petition was entertained on that basis. The Court issued notice returnable on 10.12.2024, permitted the respondent to continue the assessment proceedings in the meantime, and directed that no final order be passed during the pendency of the petition without the Court's permission.

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Issues: Whether the notice under section 148 was issued without compliance with the Scheme framed under section 135A of the Income-tax Act, 1961, including preliminary E-verification, and whether the notice was issued contrary to section 151A of the Income-tax Act, 1961.

Analysis: The petition was entertained on the basis of the contention that the Scheme under section 135A had not been followed, that no preliminary E-verification was carried out, and that the sequence of notice under section 133C and the impugned notice under section 148 was contrary to the Scheme and section 151A.

Outcome: Notice was issued returnable on 10.12.2024, and in the meantime the respondent was permitted to continue the assessment proceedings, but no final order was to be passed without permission of the Court during the pendency of the petition.

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