2024 (8) TMI 1587

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....sdiction and in violation of Section 151(1) of Income Tax Act, 1961. Ms. Agarwal, submits that in terms of Section 151(1), a scheme dated March 29, 2022, has been floated by the Revenue and in terms of the said scheme, a notice has to be issued in a faceless manner. The impugned notice dated March 28, 2024, under Section 148 of the Income Tax Act, 1961 is liable to be set aside since the same has used in violation of aforesaid scheme. Ms. Agarwal, submits that the issue has been decided by the different High Courts holding that the notice under Section 148A of the Income Tax Act should be issued only in terms of the scheme dated March 29, 2022 in a faceless manner. Ms. Agarwal, has further submitted that different Coordinate Benches o....

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.... In the High Court of Calcutta, Circuit Bench at Jalpaiguri WPA 1418 of 2024 5 M/s Indo Asian Securities Pvt. Ltd. Versus Assistant/Deputy Commissioner of Income Tax & Ors. In the High Court of Calcutta, Appellate Side WPA 14870 of 2024 6 Debapriya Dutt Vs. The Income Tax Officer, Ward 25(1) & Ors. In the High Court at Calcutta, Constitutional Writ Jurisdiction, Appellate Side WPA 11692 of 2024 At first blush, I was impressed by the submission made by Ms. Agarwal; however, after hearing Mr. Sudipto Kumar Mazumdar, ld. DSGI, I am otherwise convinced. Mr. Mazumdar has drawn attention of this court to a subsequent notice dated June 28, 2024 issued by the Income Tax Department. The said notice is quoted below : ....