JUDGMENT

Rajiv Shakdher, J. (Oral)

CM APPL. 23096/2023

1. Allowed, subject to just exceptions.

W.P.(C) 5906/2023 & CM APPL. 23095/2023[Application filed on behalf of the petitioner seeking interim relief]

2. Issue notice.

2.1. Mr Pratyaksha Gupta, Standing Counsel, accepts notice on behalf of the respondent/revenue.

3. Given the directions we propose to pass, Mr Gupta says that he does not wish to file a counter-affidavit in the matter and he will rely upon the record presently available with the court. Therefore with the consent of counsels for the parties, the writ petition is taken up for hearing and final disposal at this stage itself.

4. The petitioner has assailed the order dated 13.04.2023 passed under Section 148A(d) of the Income Tax Act, 1961 [in short, "the Act"]. In addition thereto, challenge is also laid to the consequential notice dated 14.04.2023, issued under Section 148 of the Act.

5. Counsel for the petitioner says that, apart from anything else, there has been a breach of principles of natural justice.

6. It is the submission of the counsel for the petitioner that, although a reply dated 30.03.2023 was filed, the impugned order proceeds on the basis that no r