JUDGMENT :

Manmohan, J.

1. Present writ petition has been filed challenging the order passed under Section 148A(d) and the notice issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) both dated 5th April, 2022.

2. Learned counsel for the petitioner states that the impugned order has been passed in complete violation of the principles of natural justice as well as the statutory mandate incorporated in Section 148A(c) and (d) inasmuch as the reply dated 4th April, 2022 furnished by the petitioner was not taken into consideration and an adverse inference was wrongly drawn against the petitioner by observing in the impugned order, ‘the assessee was requested to file reply to the above show cause notice on or before 04.04.2022.However, till date no response has been received from the assessee against the opportunity provided u/s l48A(b) of the Income tax Act, l961 which establishes that assessee has no explanation for issue discussed above

3. He submits that the Show Cause Notice dated 27th March, 2022 has been issued in violation of provisions of the Act as the same has been issued for verification purpose. In support of his contention he relies upon