2017 (10) TMI 542

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....e Respondent ORDER The Court :- A proceeding under Section 148 read with Section 147 of the Income Tax Act, 1961 is under challenge in the present writ petition. The petitioners also challenge a notice under Section 271 of the Act of 1971. Learned Advocate for the petitioners submits that, the Department sought to reopen the assessment for three assessment years through notices purported to ....

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....rtment submits that, the petitioners have preferred an appeal against one of the interlocutory orders passed by the Court in the present writ petition. Such appeal is pending. I have considered the rival contentions of the parties and the materials made available on record. It appears that, the Department had invoked Section 148 of the Act of 1961 in respect of three assessment years as agai....