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2022 Supreme(Chh) 511

ARUP KUMAR GOSWAMI, DEEPAK KUMAR TIWARI
Barbrik Projects Ltd. (Through Director Shri Ayush Agrawal, S/o. Shri Mahesh Kumar Agrawal) – Appellant
Versus
Union of India, through Secretary, Central Board of Direct Taxes, New Delhi – Respondent


Advocates Appeared:
For the Appellant : Mr. S. Rajeshwar Rao.
For the Respondent: Mr. Ramakant Mishra, Deputy Solicitor General, Ms. Naushina Afrin Ali.

JUDGMENT :

[Arup Kumar Goswami, J.]

1. Heard Mr. S. Rajeshwar Rao, learned counsel, appearing for the appellant. Also heard Mr. Ramakant Mishra, learned Deputy Solicitor General, appearing for the respondent No. 1 as well as Ms. Naushina Afrin Ali, learned counsel, appearing for the respondents No. 2 to 4.

2. This writ appeal filed by the petitioner is presented against an order dated 28.07.2022 passed by the learned Single Judge in WP(T) No. 186/2022 dismissing the writ petition. The writ petition was filed challenging the order dated 31.03.2022 passed by the Assessing Officer (for short, the AO) under Section 148-A of the Income Tax Act, 1961 (for short, the Act) and the notice issued under Section 148 of the Act.

3. The petitioner is a company engaged in execution of civil construction works and it had filed return of income tax under Section 139(1) of the Act for the Assessment Year (for short, AY) 2018-2019 on 26.03.2019 declaring total income at Rs.43,14,13,840/-. A notice under Section 143(2) of the Act was issued to the assessee on 23.09.2019. By an order dated 12.04.2021 passe

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