JUDGMENT

1. At the outset learned counsel appearing for the petitioner submits that the assessment order has not been passed by the respondent-Income Tax Department and submits that the controversy involved in the present writ petition is squarely covered by the ratio laid down by Jaipur Bench of this Court in the bunch of writ petitions led by D.B. Civil Writ Petition No. 969/2022:Sudesh Taneja v. Income Tax Commissioner , decided on 27.1.2022 wherein the Division Bench held as under:

"37. In this context we have perused the provisions of reassessment contained in the Finance Act, 2021. We have noticed earlier the major departure that the new scheme of reassessment has made under these provisions. The time limits for issuing notice for reassessment have been changed. The concept of income chargeable to tax escaping assessment on account of failure on the part of the assessee to disclose truly or fully all material facts is no longer relevant. Elaborate provisions are made under Section 148A of the Act enabling the Assessing Officer to make enquiry with respect to material suggesting that income has escaped assessment, issuance of notice to the assessee calling upon why notice under