JUDGMENT

Manoj Kumar Ohri, J. (Oral) - By way of present petition filed under Article 226 of the Constitution of India, the petitioner has assailed the Assessment Order dated 25.02.2022 issued by the respondent(s), whereby his self-assessment of property tax return in respect of property bearing No. 43, Rajasthani Udyog Nagar Industrial Area, G.T. Karnal Road, Delhi-110033 (hereinafter, referred to as the 'subject property') is sought to be reopened from the year 2004 onwards. The petitioner further seeks setting aside of demand bill of Rs. 41,39,433/- as well as Show Cause Notice dated 24.03.2022, issued in respect of the subject property.

2. Mr. Bhupinder Chandhok, learned counsel for the petitioner, has submitted that the petitioner is co-owner of the subject property and has been depositing the property tax in respect thereof w.e.f. the year 2004, but no notice or communication was received by him from the respondent(s) regarding said payment of tax. However suddenly, on 18.02.2022, the petitioner received a letter dated 15.02.2022 bearing No. TAX/CLZ/2021-22/634 from the respondent(s) for assessment, stating that a notice under Section 123D of the DMC (Amendment) Act, 2003 was i