TaxTMI 
TaxTMI 
2026 (9) TMI 1887
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....atter is taken up for final hearing and final disposal. 2. In the present writ petition, the petitioner has prayed for directions for quashing and setting aside the Notice issued under Section 148 of the Income Tax Act, 1961 (for short 'the IT Act') dated 29.06.2025 for Assessment Year (for short 'A.Y.') 2019-20 along with the order under Section 148A(3) of the IT Act dated 29.06.2025. 3. At the outset, learned Senior Advocate Mr. R.K. Patel appearing for the petitioner has submitted that the impugned notice as well as the impugned order are required to be quashed and set aside, since the same are bereft of any details alleging that the income to the tune of Rs. 2,14,42,208/- has escaped assessment and the same is only premised on the....
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...., without verification and drag the assessee into the reopening proceedings. Thus, it is urged that the impugned Notice as well as the order may be quashed and set aside. 5. Opposing the foregoing submissions as well as the present writ petition, learned Senior Standing Counsel Mr. Maunil G. Yajnik has submitted that the writ petition may not be entertained at this stage and the petitioner may be relegated to face the assessment proceedings. It is submitted that on the information received from the Insight portal, it was noticed by the Assessing Officer that the petitioner had entered into transactions aggregating to Rs. 2,14,42,208/- during the relevant period and on the statement recorded from Shri Nilesh Pranjivan Bhatia, it was found....
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....n the absence of exact co-relatable amount of escapement of income in each cases. The respondents have not denied these averments of the Affidavit-in-Rejoinder. Thus, it is established that the dealers like the present petitioner, who are operating in Morbi area have been subjected to issuance of Notice having verbatim similar contents and the same amounts of alleged transaction with Angadiya to the tune of Rs. 2,14,42,208/-. Interestingly, in the impugned order passed under Section 148A(3) of the IT Act, though the reply of the petitioner has been incorporated, no material has been supplied to the petitioner, no efforts are made by the Assessing Officer to verify the genuineness of the information obtained from the Insight portal. Neither ....