JUDGMENT

[Physical Hearing/Hybrid Hearing (as per request)]

Rajiv Shakdher, J. (Oral)

CM Appl.23013/2023

1. Allowed, subject to just exceptions.

W.P.(C) 5865/2023 & CM Appl.23012/2023 [Application filed on behalf of the petitioner seeking interim relief]

2. Issue notice.

2.1 Mr Gaurav Gupta, learned senior standing counsel, accepts notice on behalf of respondent/revenue.

3. In view of the order that we propose to pass, Mr Gupta says that a counter-affidavit need not be filed and he will argue the matter based on the record presently available to the court. Therefore, with the consent of the counsels for the parties, the writ petition is taken up final hearing and disposal, at this stage itself.

4. This writ petition concerns Assessment Year (AY) 2019-20.

5. The petitioner has laid a challenge to the order dated 22.03.2023 passed under Section 148A(d) of the Income Tax Act, 1961 [in short, "Act"]. Besides this, a challenge is also laid to the consequential notice of even date i.e., 22.03.2023 issued under Section 148 of the Act.

6. The principal allegation against the petitioner is that it is a beneficiary of an accommodation entry provided in the form of bogus loans, amounting to