JUDGMENT

Manmohan, J. (Oral)--Present writ petition has been filed challenging the order passed under Section 148A(d) of the Income Tax Act, 1961 (`the Act') as well as the consequential notice issued under Section 148 of the Act, both dated 30th July, 2022, for the Assessment Year 2016-17.

2. Learned counsel for the Petitioner states that reassessment was done on the allegation that sale of immovable property worth Rs.13,65,00,000/had escaped assessment. He states that the basis of the allegations are that the purchaser's PAN and Sale deeds were not on record as well as the stamp duty valuation of the transaction was not on record.

3. Learned counsel for the Petitioner states that the allegations against the Petitioner are factually incorrect. He states that the Petitioner/seller as well as the Purchaser i.e. Sh. Narinder Singh Dhingra have valid PANs and the same were also on record, inter alia, in the form of the Annual Tax Statement under Section 203AA in Form 26AS. He states that income tax return for the Assessment Year 2016-17 has been filed on 17th October, 2016 where "Revenue from Operations" have been declared unde