2023 (8) TMI 294

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....iven the directions that we propose to issue, Mr Chawla says that he does not wish to file a counter-affidavit and he will argue the matter based on the record presently available with the court. 2.1 Therefore, with the consent of learned counsels for the parties, the writ petition is taken up for hearing and final disposal, at this stage itself. 3. This writ petition concerns Assessment Year (AY) 2019-20. 4. Via this writ petition, the petitioner seeks to assail the following orders and notices: (i) Notice dated 31.03.2023 issued under Section 148A(b) of the Income Tax Act, 1961 [in short, "Act"]. (ii) Order dated 01.05.2023 passed under Section 148A(d) of the Act. (iii) Consequential notice dated 01.05.2023 issued under Section....

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.... was duly apostilled was, it appears, submitted to the Assessing Officer (AO), inter alia, in the name of persons who were referred to in the letter dated 26.04.2023. 10. It appears that since there was no response, on 09.05.2023, a letter dated 08.05.2023 was submitted by the petitioner's advocates to the AO, which, inter alia, adverted to the defences that the petitioner sought to rely upon qua the impugned reassessment proceedings that were sought to be initiated against it. 10.1 There was further correspondence on the issue in June 2023, which was initiated by the petitioner. However, what the petitioner was unaware of, was that on 01.05.2023, the impugned order was passed under Section 148A(d) of the Act. 10.2 This order, evidently,....