S. RAVINDRA BHAT, J.

Facts

1. The present batch of Writ petitions challenges the constitutionality of the amendment of Section 142(2A) of the Income Tax Act, 1961 (hereafter “the Act”). Since the question raised for the Court’s consideration is the same in all of these writ petitions, the facts in W.P.(C) 9138/2015 are taken as reference and are described below.

2. Shri Dhir Chand Sharma, (hereafter, the “petitioner” or the “assessee”) is a contractor and during the assessment year in question it was engaged in the business of supplying earth materials. Search and seizure operations were carried out under Section 132 of the Income Tax Act, 1961 (hereafter “the Act”) in M/s. NKG and the petitioner who at the time was undertaking contract work for M/s. NKG was also subject to search and seizure operations under Section 132. A notice under Section 153A was issued to the petitioner and in response, the petitioner filed return for the assessment year (AY) 2010-11 declaring income of Rs.8,56,148/-. Notices were issued to the petitioner under sections 143(2) and 142(1) of the a