2006 (3) TMI 132

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....ition by the assessee under article 226/227 of the Constitution of India. In this petition, the petitioner seeks to impugn the legality and validity of the notice dated March 30, 2005, issued by the Assessing Officer under section 148 of the Income-tax Act, 1961 (Annex. C/1). This notice is sought to be impugned by the petitioner, inter alia, on the ground that it is barred by limitation as pro....

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....notice was signed, (ii) on what date it was issued, and lastly (iii) on what date it was served upon the assessee, needs to be examined on the facts and with reference to the original record of the case and for that purpose some enquiry is needed at the level of the Assessing Officer. The writ court is not the proper forum to hold such enquiry though limited in nature. I, therefore, while dispo....