JUDGMENT

B.N. MAHAPATRA, J. : This review petition has been filed with a prayer to review the judgment dated 15.12.2011 passed by this Court in W.P.(c) No.4554 of 2011 on the ground that the said judgment suffers from error/mistake due to incorrect appreciation of facts and circumstances involved as well as the same is contrary to the settled position of law with respect to the issues involved.

2.Besides the ground of challenge stated above, which is general in nature, Mr. N.L. Das, learned counsel appearing for the review petitioner challenges the impugned judgment on the following specific grounds;

(i)The notice under Section 143(2) of the Income Tax, 1961 (in short, ‘the Act’) was issued to the petitioner on 10.10.2007 followed by the notice under Section 142(1) of the Act on 03.10.2008. According to Mr. N.L. Das, the notice under Section 42(1) is the initiating point of an assessment. Section 142 of the Act states “Inquiry before Assessment” and the hearing under Section 143 is “Assessment”. Thus, the very intent of the statute in designating such hearing is clearly manifested in the idea that there has to be an initiation of assessment proceeding under Section 142(1) and only aft