2026 (10) TMI 1346

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.... 1. The present writ petition has been filed by the petitioner assailing the order dated 19.06.2025 passed under Section 148A(3) of the Income Tax Act, 1961 by the Income Tax Officer, whereby proceedings for reassessment for the assessment year 2019-20 were initiated, along with the consequential notice dated 19.06.2025 issued under Section 148 of the Act. 2. A complaint was made by one Smt. Lajwanti Devi before the Collector (Stamps), Hanumangarh Camp, Sriganganagar, alleging that the petitioner had entered into an agreement dated 28.10.2018 with non-petitioner No.4 for purchase of agricultural land measuring 48.10 bighas for a consideration of Rs.2,91,00,000/-, without registration of the agreement and payment of stamp duty. 2.1 Su....

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.... pending proceedings before this Court. It is contended that the alleged executant, Amritpal Singh, has denied execution of the agreement, receipt of consideration and transfer of possession, while the document has also been alleged to be forged and fabricated. Despite the same, the respondents have treated the recital of consideration as proof of actual cash payment without any independent corroborative material establishing such payment. 3.1 Learned counsel also submits that the petitioner's detailed reply and the material placed on record were not duly considered and that the order under Section 148A(3) was passed without independent application of mind. It is contended that the requisite sanction under Section 151 was not obtaine....