2022 (4) TMI 596

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.... Mr. Sandeep Goel and Mr. Venkatesh Chaurasia, Advocates. Respondent Through: Ms. Vibhooti Malhotra, Sr. Standing Counsel with Mr. Shailendra Singh, Jr. Standing Counsel and Mr. Udit Sharma, Advocates. J U D G M E N T MANMOHAN, J (Oral) 1. Present writ petition has been filed challenging the order dated 28th March, 2022 passed by Respondent under Section 148A(d) of the Income Tax Act, ....

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....cing reliance on the information provided by the investigation wing which does not have any rational nexus with the petitioner. He states that the information mentioned in the Show Cause Notice pertains to the Assessment Year 2014-15 which has been used to frame reason to believe escapement of income for the Assessment year 2018-19. 4. A perusal of the paper book reveals that in the impugned or....

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....r, this Court is of  the view that the ratio of the Supreme Court judgment in Raymond Woollen Mills Ltd. vs. Income-tax Officer, Centre Circle XI, Range Bombay and Ors. (2008) 14 SCC 218, is clearly attracted to the facts of the present case inasmuch as in the said judgment it has been held, "In determining whether commencement of reassessment proceedings was valid it has only to be seen whet....

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...., 1961 provides complete machinery for assessment/reassessment of tax, assessee is not permitted to abandon that machinery and invoke jurisdiction of High Court under Article 226. Consequently, the present case does not fall under the exceptional grounds on which a writ petition is maintainable at the interim stage in tax matters. [See: Ghanashyam Mishra And Sons Private Limited Vs. Edelweiss Asse....