JUDGMENT :

Manmohan, J.

1. Present writ petition has been filed challenging the notice dated 27th March, 2022 under Section 148 of the Income Tax Act, 1961 (‘the Act’) for the Assessment Year 2018-19 pursuant to an order passed under Section 148A(d) of the Act on 27th March, 2022 by the Respondent No.1.

2. Learned counsel for the Petitioner states that the Petitioner was asked to comply with the Show Cause Notice dated 21st March, 2022 by 25th March, 2022, thereby not giving him the minimum statutory prescribed time of seven days to reply to the notice.

3. He points out that the notice under Section 148A(b) of the Act was issued by the Respondent No. 1 on 21st March, 2022 for the Assessment Year 2018-19 stating that the Petitioner has claimed bogus Long Term Capital Gains (‘LTCG’) of Rs.1,23,21,875/- on purchase and sale in the shares of M/s Achal Investments Ltd. However, he points out that the next paragraph of the notice stated that the income chargeable to tax has escaped assessment for the Assessment Year 2015-16, making the notice self-contradictory.

4. He further states that the notice mentioned that the evidence pertaining to the said information had been enclosed but the same w