ORDER :

1. By filing this writ application, under Article 226 of the Constitution of India, the writ applicant seeks to challenge the impugned notice dated 26.02.2019 issued under Section 148 of the Income Tax Act, 1961 seeking to reopen the applicant’s assessment for the A.Y. 2013-14.

2. The brief facts can be summarized as under:

The assessee filed his return of income for A.Y. 2013-14 on 29.01.2014 declaring total income at Rs. 24,52,260/- whereby, the assessee had claimed the exempt income Rs. 15,00,000/- received as a gift from his brother-in-law. The return was processed under Section 143(1) of the Act on 10.07.2014 and thereafter, the case was selected for scrutiny assessment. During the scrutiny proceedings, the details called for were placed on record. The assessing officer had asked the details regarding receipt of gift of Rs. 15,00,000/-. The assessee vide letter dated 11.01.2016 furnished various details including his explanation with regard to gift received from his brother-in-law amounting to Rs. 15,00,000/- and in support thereof, the copy of declaration of gift made by Mr. B.U. Patel (brother-in-law of the assessee) was also submitted. The assessment order under Sectio