JUDGMENT :

Surya Prakash Kesarwani, J.

1. Heard learned counsel for the petitioners, Sri S.P. Singh, learned Additional Solicitor General of India assisted by Sri Krishna Agrawal and Sri Praveeen Kumar, learned counsel for the respondents in all the above-noted writ petitions.

2. These writ petitions have been filed praying to quash the notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act, 1961’) and the reassessment orders passed under Section 147/148 of the Act, 1961.

3. Since common questions of law on similar set of facts are involved in this batch of writ petitions, therefore, with the consent of learned counsels for the parties, the Writ Tax No.554 of 2022 have been heard as a leading writ petition and facts of this case are being noted.

4. In the above noted writ petitions, the following reliefs have been sought by the petitioners:

“WRIT TAX No. 554/22

(I) Issue a writ, or direction in the nature of Certiorari quashing the impugned notice u/s 148 of the Act, dated 31.03.2021, issued by respondent no.3, for A.Y. 2013-14. (Annexure No. 4)

(ii) Issue a writ, order or direction in the nature of Prohibition thereby restraining Respondent No. 3 from un