Planet Plaza Private Limited vs Income Tax Officer on 6 February, 2025

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The Court: Affidavit-of service filed by the petitioner is kept on record.

Learned counsel appearing for the petitioner files supplementary affidavit.

Let the supplementary affidavit also be kept with the record.

Learned Counsel for the petitioner submits that the petitioner challenges

the notice issued under section 148 of the Income Tax Act, 1961 on the ground,

inter alia, that the same has been issued by the jurisdictional assessing officer

though in terms of section 151A of the said Act read with the notification dated

29th March 2022, such notice was required to be issued through the automated

allocation, in accordance with the risk management strategy formulated by the

Board as referred to section 148 of the said Act, for issuance of notice, in a

faceless manner, to the extent provided in section 144B of the Act with reference

to making assessment or re-assessment of the total income or loss of the

assessee.

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