The challenge in the present writ petition is to order dated 30.06.2022
passed under Section 148A(d), the consequential notice dated 30.06.2022 under
Section 148 issued by respondent No.1 – Income Tax Officer, Ward-1,
1, Karnal.
Karnal
Further challenge is to the show cause notice dated 10.03.2025 issued by
respondent No.2 – National Faceless Assessment Centre.
BRIEF FACTS
2. Brief facts of the present case are that notice under Section 148 of the
Income Tax Act was issued to the petitioner on 16.04.2021 i.e. after 01.04.2021,
which is the date of coming into force of Finance Act, 2021 whereby Sections 147
to 151 of the Income Tax Act, 1961 were substituted. Therefore, in compliance of
CWP-7405-2025(O&M)
2025(O&M) -2-
judgment dated 04.05.2022 passed by the Hon’ble Supreme Court in Union of
India and Others Vs. Ashish Aggarwal,
Aggarwal, respondent No.1 (Income Tax Officer,
Ward-1,
1, Karnal) issued notice under Section 148A(b) of the Act on 19.05.2022.
The petitioner filed reply to the same with certain objections regarding jurisdiction
under Section 147 of the Income Tax Act and after considering the reply,
reply
respondent No.1 (Income Tax Officer, Ward-1,
1, Karnal) disposed of the objections
raised by the petitioner and proceeded to pass an order under Section 148A(d) on
30.06.2022, confirming jurisdiction to reassess income of the petitioner under
Section 147 of the Income Tax Act and issued consequential notice under Section
Sectio
148 of the Income Tax Act dated 30.06.2022 initiating the assessment under
Section 147 of the Income Tax Act. The petitioner challenged the notice dated
30.06.2022 and consequential proceedings by filing CWP
CWP-2986-2023
2023 on
14.03.2023, which was ultimately dismissed on 20.12.2024 by this Court in terms
of judgment passed in CWP-18488-2022
CWP 2022 titled as M/s Patran Foods Pvt. Ltd. Vs.
Union of India and Others.
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