2023 (3) TMI 366

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....ARORA For the Petitioner : Mr.Ved Kumar Jain, Advocate with Mr.Nishchay Kantoor and Ms.Richa Mishra, Advocates. For the Respondents : Mr.Sanjay Kumar, Advocate with Ms.Easha Kadian, Advocate for revenue. JUDGMENT MANMOHAN, J (Oral): 1. Present writ petition has been filed challenging the notice dated 7th April, 2021 issued by Respondent No. 1 under Section 148A(b) of the Income Tax ....

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....ises that though Respondent No.1 has itself observed in the impugned order under Section 148A(d) of the Act that the amount alleged to have escaped assessment is below the threshold of Rs.50,00,000/-, yet Respondent No. 1 issued notice under Section 148 of the Act. The relevant extract of the order is reproduced hereinbelow: - "6.10 Similarly as far as transaction amounting to Rs.926187/-....

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....evenue, accepts notice. He states that he has no instructions in the present case. He, however, does not dispute that the income alleged to have escaped assessment is less than Rs.50,00,000/-. 4. This Court is of the view that the reopening in the present case is in violation of CBDT Instruction No.01/2022 dated 11th May, .2022, wherein it has been clearly stated that notices in the cases perta....