JUDGMENT :

1. Heard Sri. Parv Agarwal, learned counsel for the petitioner and Sri. Gaurav Mahajan, learned Senior Standing Counsel for the Income Tax Department.

2. This writ petition has been filed praying for the following reliefs:

“(a) Issue a writ, order or direction in the nature of certiorari quashing the notice dated 30.03.2021 issued by the respondent no. 2 under Section 148 of the Act as also the order dated 28.02.2022 passed by respondent no. 3, rejecting the objections filed by the petitioner against the reasons to believe for assumption of jurisdiction against the petitioner for the Assessment Year 2015-16.

(b) Issue a writ, order or direction in the nature of mandamus restraining the respondents from proceeding with the reassessment proceedings against the petitioner for the AY-2015-16.”

3. The only argument advanced by the learned counsel for the petitioner before us is that the normal period of limitation for issuing notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the Act of 1961) would be six years where escapement of income from tax is one lacs or more. In this regard, he referred to the provision of Section 149(1) (b) of the Act of 1961