1. This is the second round of litigation initiated by the petitioner to
challenge the proceedings issued under section 148A of the Income Tax
Act, 1961 (hereinafter referred to as ‘the said Act’) which ultimately
culminated in the order passed under section 148A(d) of the said Act
dated 22nd January, 2025 in respect of the assessment year 2019-20.
Following the above, a notice under section 148 of the said Act for the
relevant assessment year dated 22nd January, 2025was also issued. .
2. Records would reveal that the petitioner had previously approached this
Court by filing a writ petition which was registered as WPO/556/2024.
By an order dated 20th August 2024, this Court taking note of the
submissions made by the petitioner and considering the fact that in
absence of the respondents disclosing the basis on which the show
cause notice had been issued under section 148A(b) of the said Act, had
proceeded to set aside the order passed under section 148A(d) of the
said Act dated 26th April, 2023 with a further direction upon the
respondents to make available the basis of information based on which
the notice under section 148A(b) of the said Act was issued. The above
order was communicated by the petitioner to the respondents by
communication in writing dated 24th August, 2024. Pursuant to the
above, the petitioner was offered an opportunity of hearing as would
appear from the communication dated 18th September, 2024. Following
the above, the petitioner once again by letter dated 25th September,
2024 reiterated its earlier stand by highlighting the order passed by this
Court on 20th October, 2024. Records would also reveal that only
thereafter, the respondents by an electronic mail on 9th October, 2024
had favoured the petitioner with the documents/information on the
basis of which notice under section 148A(b) of the said Act dated 31st
March, 2023 was issued so as to support the case of undisclosed
income of Rs.40,00,000/- which had escaped assessment.