ORDER :

(Bhargav D. Karia, J.)

1. By this petition under Article 226 of the Constitution of India, the petitioner has challenged the notice dated 13th April 2022 issued under Section 148 of the Income Tax Act, 1961 (for short, “the Act”) for the Assessment Year 2018-19.

2. The brief facts of the case are as under:

2.1 The petitioner is a company incorporated under the Companies Act, 1956. The petitioner filed return of income showing total income of Rs.61,24,830/- for the Assessment Year 2018-19.

2.2 The respondent – Assessing Officer issued notice under Section 148A(b) of the Act calling upon the assessee as to why reassessment proceedings should not be initiated by issuing show cause notice under Section 148 of the Act on the following grounds:

- As per information received by the respondent. M/s S.K. Enterprises, Ahmedabad (i.e. a third party) was involved in availing incorrect Input Tax Credit (hereinafter referred to as "ITC" for the sake of brevity) as well as passing on ITC to others without actual supply of goods.

- Reference has been made to statements of Shahrukhkhan Pathan and Madhav Shah recorded by the department. In view of the same and certain other aspects, it was con