Failure to provide the mandatory seven-day notice period under Section 148A(b) invalidates tax assessments, establishing procedural compliance as crucial in tax law.

ORDER :

S.R.KRISHNA KUMAR, J.

In this petition, petitioner seeks for the following reliefs:-

“a. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 148A(b) of the Income Tax Act, 1961 dated 23/03/2022 issued by the Respondent No. 1 for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/F/148A(SCN)/ 2021-22/1041332854(1) and enclosed as Annexure –B1.

b. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated order u/s 148A(d) of the Income Tax Act, 1961 dated 04/04/2022 issued by the Respondent No. 1 for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/F/148A/2022-23/1042494205(1) enclosed as Annexure C.

c. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice u/s 148 of the Income Tax Act, 1961 dated 04/04/2022 issued by the Respondent No. 1 for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/S/148_1/2022-23/1042496210(1)and enclosed as Annexure D.

d. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated assessment order under section 147 r.w.s 144 r.w.s. 144B of the Income Tax Act, 1961 dated 05/03/2024 passed by the Respondent No. 3 for the Assessment Year 2015-16 which bears the DIN viz., ITBA/AST/S/147/2023-24/1062006966(1) and enclosed as Annexure J1.

e. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice of demand under section 156 of the Income Tax Act, 1961 dated 05/03/2024 issued by the Respondent No. 3 for the Assessment Year 2015- 16 which bears the DIN viz ITBA/AST/S/156/2023-24/1062007139(1) and enclosed as Annexure J2.

f. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated computation of income dated 05/03/2024 issued by the Respondent No. 3 for the Assessment Year 2015-16 which bears the DIN viz ITBA/AST/S/114/2023-24/1062007200(1) and enclosed as Annexure J3.

g. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice for penalty under section 274 r.w.s 271(1)(c) of the Income-tax Act, 1961 dated 05/03/2024 issued by the Respondent No. 3 for the Assessment Year 2015-16 which bears the DIN viz and ITBA/PNL/S/271(1)(c)/2023-24/1062007070(1)enclosed as Annexure K1.

h. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice for penalty under section 274 r.w.s 271(1)(b) of the Income-tax Act, 1961 dated 05/03/2024 issued by the Respondent No. 3 for the Assessment Year 2015-16 which bears the DIN viz and ITBA/PNL/S/271(1)(b)/2023-24/1062007078(1)enclosed as Annexure K2.

i. Issue a writ of certiorari or any other suitable writ for quashing of the digitally signed and electronically communicated notice for penalty under section 274 r.w.s 271F of the Income-tax Act, 1961 dated 05/03/2024 issued by the Respondent No. 3 for the Assessment Year 2015-16 which bears the DIN viz ITBA/PNL/S/271F/2023-24/1062007090(1) and enclosed as Annexure K3.

j. Grant such other reliefs as this Hon'ble Court deems fit in this matter including but not limited to COSTS OF THIS PETITION.”

2. Heard learned counsel for the petitioner and learned counsel for the respondents and perused the material on record.

3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned counsel for the petitioner invites my attention to the impugned Notice da