2026 (9) TMI 1471

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....By way of the present writ petition, the petitioner has challenged the proceedings initiated against the petitioner under Section 148 of the Income Tax Act, 1961 ('hereinafter referred to as the Act of 1961'), on various grounds, but mainly on the ground of change of opinion. 2. Mr. Porus Kaka, learned Senior Counsel appearing for the petitioner invited Court's attention towards the facts of the case and submitted that the petitioner's assessment was made under Section 147 read with Section 144C(13) of the Act of 1961, vide order dated 26.12.2025 taking into consideration transaction of Rs. 29,66,29,69,168. He added that after examining all aspects of the matter, including the nature of transaction and receipts, the petitioner's returned....

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....gainst the petitioner under Section 148 of the Act of 1961. 6. Mr. Indruj Singh Rai, learned Senior Standing Counsel for the respondents on the other hand submitted that petitioner's assessment was made after considering figure of Rs. 29,66,29,69,168/- only, whereas the amount reflected in Risk Management Strategy portal is Rs. 45,84,61,34,343/-. He asserted that in spite of the notice so issued, the petitioner gave an evasive and unsatisfactory reply and failed to provide details, tabulation/chart, etc., so as to enable reconciliation of the figures, so that the difference or discrepancy as noticed by the AO can be resolved/sorted. 7. Heard rival counsel. 8. The case set up by the petitioner is, that the AO is seeking to conduct a....