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2022 Supreme(All) 1031

SURYA PRAKASH KESARWANI, JAYANT BANERJI
S. R. Cold Storage – Appellant
Versus
Union Of India – Respondent


Advocates Appeared:
For the Petitioner: Abhinav Mehrotra, Satya Vrata Mehrotra.
For the Respondent: A.S.G.I., Gaurav Mahajan.

JUDGMENT :

(Surya Prakash Kesarwani, J.)

1. Heard Sri Abhinav Mehrotra, learned counsel for the petitioner, Sri S.P. Singh, learned Additional Solicitor General of India, assisted by Sri Anant Kuma Tiwari, learned counsel for the respondent no.1 and Sri Gaurav Mahajan, learned Senior Standing Counsel for the Income Tax Department-Respondent Nos. 2, 3, and 4.

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

    “I. To issue a writ, order or direction in the nature of CERTIORARI quashing the Impugned Notice issued under Section 148 of the Income Tax Act Dated 31.03.2021 [Annexure No. 2 (coll)] r/w Order Dt. 24.03.2022 [Annexure No. 9] issued by the Respondent No.2 and the connected proceedings for Reassessment of Income for A.Y. 2017-18.

    II. To issue a writ, order or direction in the nature of Certiorari Quashing the Re-Assessment Order for the Assessment Year 2017-18, Dt. 31.03.2022 [Annexure No.13] which is made in gross violation of law and principles of Natural justice.

    III. To issue a writ, order or direction in the nature of MANDAMUS declaring that Amendment c

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