ORDER :

C. Praveen Kumar, J.

1. Assailing the Order made under Clause (d) of Section 148A of Income Tax Act, 1961 [‘the Act’], wherein the Authority on coming to the conclusion that, income chargeable to tax, which is in the form of an asset, is likely to amount to Rs.50,00,000/- or more, which escaped the assessment, leading to issuance of notice under Section 148 of the Act, the present Writ Petition is filed.

2. The facts, in issue, are as under :

i. The Petitioner herein is involved in business of Fish farming. Basing on the information received under the category of ‘NMS Module of insight portal’ and as no declaration was filed for the assessment year 2015-2016, the Petitioner’s case was taken up by the first Respondent under Section 148A(a) of the Act.

ii. A Notice came to be issued under Section 148A(b) of the Act, on 20.03.2022 i.e., before the end of the period of six [06] years from the end of the relevant assessment year, to which the Petitioner is said to have submitted an explanation under Section 148A(c) of the Act, on 21.03.2022. Taking into consideration the explanation submitted by the Petitioner, the Authorities felt that it is a fit case for issuance of notice under S