JUDGMENT :

R.D. Dhanuka, J.

1. Rule. Mr. Alok Sharma, the learned counsel waives service for respondent Nos. 1 to 3. Rule is made returnable forthwith.

2. By this petition filed under Article 226 of the Constitution of India, the petitioner has impugned the notice dated 31.03.2021 issued by the respondent No. 2 U/Sec. 148 of the Income Tax Act, 1961 (for short “I.T. Act”) and also order dated 01.03.2022 passed by the respondent No. 3 thereby rejecting the objection filed by the petitioner.

3. On 28th March, 2018, the petitioner filed his return of income tax for the assessment year 2016-2017. On 31.03.2021, the respondent No. 2 issued notice U/Sec. 148 of the I.T. Act to the petitioner for reassessment of the assessment year 2016-2017. On 01.04.2021 Finance Act, 2021 came into force and entire mechanism of reopening of assessment U/Sec. 147 to 151 of the Income Tax Act has been changed.

4. The respondent No. 2 supplied the copy of the reasons recorded before issuance of the impugned notice to the petitioner. On 24.02.2022 the petitioner filed objection to the reasons recorded and specifically raised objection regarding tenability of the proceedings. On 01.03.2022, the respondent No. 3 r