2025 (5) TMI 1803

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....ner has filed the present petition, inter alia, praying as under: "1) Issue a writ of CERTIORARI or any other appropriate writ, order or direction for quashing the impugned notice u/s 148 dated 28.08.2024, Impugned Order u/s 148A (d) dated 28.08.2024 and impugned Show Cause Notice u/s 148A (b) dated 13.08.2024 of the Income Tax Act, 1961 in the petitioner's case for Assessment year 2018-19, being patently bad in law, without jurisdiction, violative of statutory principles of interpretation, and in violation of the provisions of the said income tax act, 1961 and the principles of natural justice and other Consequential proceedings; 2) Issue a writ of Prohibition or any other appropriate writ, order or direction to prohibit the Responden....

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....Act. ii. The supervisory authorities are hereby advised to keep an effective supervision SO as to ensure that all extant Instructions/Guidelines/Circulars/SOPs are duly followed by the Assessing Officers in their charge. 5. He submits that in the present case, the impugned notice under Section 148A (b) was issued on the basis of statement of one Sh. Shitij Malhotra who claimed that he had not engaged in any business activity but has earned his income through issuing bogus bills of purchases and sales on entry basis. He also claimed that he had earned a nominal commission of 1% of the amount deposited/credit in his accounts. The learned counsel submits that copy of the statement was also not provided to the Petitioner therefore he was not....