% 20.03.2025
1. The petitioner has filed the present petition, inter alia, impugning a
notice dated 31.08.2024 [impugned notice] issued under Section 148 of the
Income Tax Act, 1961 [the Act] in respect of the assessment year [AY]
2014-15. The petitioner contends that the said notice is beyond the period of
limitation as stipulated under Section 149(1) of the Act and therefore is
liable to be set aside.
2. The impugned notice was preceded by a notice dated 06.08.2024
issued under Section 148A(b) of the Act. The annexure appended to the said
notice sets out the information which according to the Assessing Officer
[AO] is suggestive of the petitioner’s income for the AY 2014-15 escaping
assessment. The said notice indicates that on 13.07.2020 a search was
conducted at various premises in connection with “Om Kothari Group” of
Rajasthan. It was alleged that during the course of investigation, evidence
was found regarding details of flats sold in a project named Pallacia and
This is a digitally signed order.