(per Hon’ble Sri Justice P.Sam Koshy)
Heard Mr. S.Vijay Adithya, learned counsel for the petitioner
and Ms. J.Sunitha, learned Senior Standing Counsel for the Income Tax
Department appearing for the respondent Nos.1 to 3, and Mr.
G.Naresh, learned counsel representing Mr. Gadi Praveen Kumar,
learned Deputy Solicitor General of India, appearing for respondent
No.4. Perused the record.
2. This is a writ petition where the proceedings are either
challenged to the notices which were issued under Section 148A and
148 of the Income Tax Act, 1961 (for short ‘the Act’) or the assessment
orders those have been passed under Section 147 of the Act which
have been assailed.
3. This writ petition is being taken up today only on one of the
grounds, that the notices issued under Section 148A of the Act and the
subsequent initiation of proceedings under Section 148 of the Act by
the jurisdictional Assessing Officer, whereas in terms of the
amendment that was brought to the Income Tax Act by way of Finance
Act, 2021 w.e.f., 01.04.2021 onwards, proceedings under Section 148A
of the Act as also under Section 148 of the Act ought to have also been
issued and proceeded in a faceless manner.