2021 (5) TMI 460

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..../s.G.R.Associates For the Respondent : Mr.A.P.Srinivas, Senior Standing Counsel for Income Tax. ORDER The notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the 'Act', in short) issued by the respondent in proceedings dated 24.03.2018 for the assessment year 2011-2012 is under challenge in the present writ petition. 2. The learned counsel appearing....

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.... objections thereon regarding the proceedings initiated under Section 147 of the Act. Only after following the principles laid down by the Apex Court in the case of GKN Driveshafts (India) Ltd (cited supra), the petitioner would be in a position to know on what basis the reopening of assessment initiated under Section 148 of the Act and therefore, the writ petition is not maintainable and is liabl....

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....er is at liberty to raise the same before the Authority Competent and certainly not before this Court. 7. The notice under Section 148 of the Act, which is impugned in the present writ petition, reveals that the respondent has reason to believe that the income chargeable to tax for the assessment year 2011-2012 has escaped assessment within the meaning of Section 147 of the Act. 8. Thus the ....