JUDGMENT :

Jitendra Jain, J.

1. This petition is instituted by the petitioner challenging an order passed under Section 148A(d) and notice under Section 148 of the Income Tax Act, 1961 (‘the Act’), both dated 28 March 2024 for the assessment year 2017-18.

Brief facts :-

2. The petitioner is an individual and has filed his return of income for assessment year 2017-18 on 3 August 2017. The said return of income was selected for scrutiny by issuing a notice under Section 142(1) of the Act for examining the claim of deduction under Section 57 of the Act. In the petition at Exhibit ‘C’, there is a copy of the email response submitted by the petitioner during the course of original assessment proceedings in which reference is made to evidence in support of the nexus between the income from other sources and deduction against that income. However, surprisingly, the enclosures to this Exhibit ‘C’ are not annexed in the present petition.

3. On 24 December 2019, an assessment order under Section 143(3) of the Act came to be passed accepting the returned income. The said assessment order does not refer to the response filed by the petitioner at Exhibit ‘C’ to the petition. Still, it states that th