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2021 Supreme(Ori) 467

B.P.ROUTRAY
Viresh Hemani – Appellant
Versus
Income Tax Officer, Ward-3, Rourkela – Respondent


Advocates Appeared:
Mr. Sidharth Ray, Advocate, for the Appellant; Mr. S.S. Mohapatra, for the Respondent.

ORDER

1. This matter is taken up by video conferencing mode.

2. The challenge in this writ petition is to a notice dated 21st May, 2013 issued by the Income Tax Officer ('ITO'), Ward-3, Rourkela to the Petitioner proposing to reassess the income for the Assessment Year (AY) 2007-08 under Section 147 of the Income Tax Act, 1961 ('the Act') on the ground that the income chargeable to tax for the said AY has escaped assessment.

3. While directing issuance of notice in the present writ petition on 20th October, 2014, an interim order was passed directing that the proceedings against the Petitioner may continue, but no final order shall be passed pursuant to the impugned order.

4. The background facts are that the Petitioner is the proprietor of M/s. Pratik Tours and Travels which is in the business of selling of AIR Tickets and Tour Packages. The Petitioner filed his return of income for the AY 2007-08 on 29th October 2007. More than five years thereafter, the Petitioner received the impugned notice dated 21st May, 2013, in response to which by letter dated 15th July, 2013, the Petitioner assessee requested the ITO to inform him of the reasons for the reopening. Prior thereto on 21st June,

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