2022 (1) TMI 1230

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.... questioned the notice issued under Section 148 of the Income Tax Act on 30.03.2021 in W.P.No.17262 of 2021. 4. The said writ petition was disposed by an order dated 18.08.2021. The aforesaid notice sought to reopen the assessment beyond the normal period of limitation under Section 147 of the Income Tax Act, 1961 (hereinafter referred to as the IT Act) almost at the fag end of the limitation period prescribed under Section 147 of the IT Act. Pursuant to the aforesaid notice, the respondent has passed the impugned order disposing/over ruling the objection of the petitioner against reopening of the Assessment under Section 148 of the IT Act. 5. The learned counsel for the petitioner submits that the reasons for reopening the assessment....

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....ench of this Court had interfered by setting aside the order of the learned Single Judge of this Court and therefore submits that the writ petition filed by the petitioner deserves to be allowed. 11. Opposing the prayer, the learned Senior Standing Counsel for the respondent submits that the impugned order is well-reasoned and requires no interference. 12. It is submitted that the impugned order merely communicated the reasons for reopening the assessment and the assessment has to be completed and it is open for the petitioner to give additional inputs for dragging the proceedings. 13. Heard the learned counsel for the petitioner and the learned Senior Standing Counsel for the respondent. 14. There are several disputed questions....