JUDGMENT :

The petitioner has approached this Court being aggrieved by the fact that proceedings have been initiated against the petitioner under Section 148 of the Income Tax Act, 1961 (as it stood before 01.04.2021), despite the fact that, notice under Section 148 of the Income Tax Act was received by the petitioner only after 01.04.2021. The petitioner has a case that the proceedings are in violation of the principles of natural justice. It is also contended that the ‘National Faceless Assessment Scheme’ is ‘ultra vires the Constitution and hence void’.

2. The petitioner, a partnership firm, is an asessee under the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). It received Ext.P.2 notice dated 30.3.2021 issued under Section 148 of the Act. The notice pertains to the assessment year 2015-16. According to the petitioner, the said notice was received by the petitioner only on 15.4.2021. This was followed by Ext.P.3 notice issued on 14.9.2021 under Section 142(1) of the Act calling for information from the petitioner for finalizing the assessment. The petitioner responded to this notice by submitting Ext.P.4 reply. A further notice (Ext.P.5) was issued under the same pro