2025 (8) TMI 1189

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....iled this present petition under Article 226 of the Constitution of India seeking quashment of notice dated 29.02.2024 under Section 148A(b) and the impugned order dated 29.03.2024 under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as the 'IT Act') issued by respondent No.1. The petitioner is also seeking quashment of notice dated 29.03.2024 issued under Section 148 of the IT Act issued by respondent No. 1 in respect of assessment of the income for the Financial Year 2019-2020 and Assessment Year 2020-2021. Brief facts of the case are as under : 3. M/s. Nivedan Commerce Pvt. Ltd. was a company registered under the Companies Act, 1956. M/s Nivedan Commerce Pvt. Ltd., M/s Suvidhinath Commercial Ltd., M/s Patwari ....

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.... return was found to be filed. The petitioner submitted a reply to the effect that on account of merger w.e.f. 01.04.2018 no notice could have been issued to M/s Nivedan Commerce Pvt. which is not in existence. The aforesaid contention was not accepted and the respondent No. 1 has passed an order under Section 148A(d) of the IT Act on 29.03.2024 for issuance of notice under Section 148 of the IT Act. Now, the petitioner has been served with a notice dated 29.03.2024 under Section 148 for furnishing the return for the AY 2020-2021. Hence, this petition before this Court. Submissions of respondents 6. The respondent No.1 filed reply by submitting that as per the information under the Risk Management Strategy devised by the Central Board....