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2022 Supreme(Raj) 476

Parmesh Chand Yadav S/o Rameshwar Lal Yadav – Appellant
Versus
Income Tax Officer, Jaipur – Respondent


Advocates:
Advocate Appeared:
For the Petitioners: Mr. Nikhil Yadav, Mr. Vedant Agarwal, Mr. Abhil Goyal.
For the Respondents: Mr. Amit Malani, Mr. Nikhil Simlote.

ORDER :

1. Heard.

2. In this petition, reply has not been filed, the same stands closed.

3. Challenge in this petition is to impugned order dated 31.03.2022 passed by the Assessing Authority in exercise of power under Section 148A of the Income Tax Act, 1961 (herein referred to as “the Act of 1961”) leading to issuance of notice under Section 148 in the matter of reopening of the assessment proceedings for the assessment year 2018-2019.

4. The bare facts necessary for adjudication of controversy involved in this petition are that the petitioner and income tax payee, for the assessment year of 2018-19 submitted his income tax returns and assessment proceedings were drawn.

5. A notice, however, came to be issued by the Assessing Officer on 19.3.2022. Notice Under Sub-Clause (b) of Section 148A of Act, 1961 came to be issued to the petitioner stating that information received suggests that income chargeable to tax for the assessment year 2018-19 has escaped assessment within the meaning of Section 147 of the Act, 1961. Alongwith the said notice, details as part of the annexure were also disclosed that as per higher risk CRIU/VRU information flagged by the Directorate of Income-Tax (systems

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