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2022 Supreme(Raj) 1869

SANDEEP MEHTA, REKHA BORANA
Ganesh Ram Choudhary – Appellant
Versus
Union Of India – Respondent


Advocates appeared:
Mr. Sharad Kothari, Mr. Mayank Taparia, for the Appellant.

ORDER

Rekha Borana, J. - The present petition has been filed aggrieved of the notice dated 30.03.2021 issued under Section 148 of the Income-tax Act, 1961 (for short, 'Act of 1961') seeking to reopen assessment and the order of dismissal of the objections against the same.

2. The petitioner has pleaded in the writ petition as under:

3. The petitioner was in receipt of summons dated 20.01.2017 issued under Section 131(1A) of the Act of 1961 requiring him to furnish information and documents concerning nature of his business, source of income and books of accounts including bank statements. The said summons was followed by further summons dated 14.02.2017, 26.05.2017, 09.11.2017 and 27.11.2017. A reply to the said summons was ultimately filed by the petitioner on 20.02.2018 whereby, the documents and the information as called for were submitted. But after a period of 3 years of the reply being furnished by the petitioner, he was served with the notice dated 30.03.2021 under Section 148 of the Act of 1961 seeking to reopen assessment on the grounds that the income chargeable to tax for the assessment year 2013-14 has escaped assessment. Vide the said notice, the income-tax return in the

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