JUDGMENT :

1. Heard Shri Rahul Agarwal, learned counsel for the petitioner and Shri Gaurav Mahajan, learned Senior Standing Counsel, for the revenue.

2. Challenge has been raised to the order dated 27.03.2024 passed under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as the 'Act') and the consequential notice of the same date, issued under Section 148 of the Act for the Assessment Year 2020-21.

3. For the Assessment Year 2020-21, the petitioner had filed his regular return of income. However, no scrutiny assessment arose in his case. On 19.02.2024, a show cause notice was issued to the petitioner under Section 148A(b) of the Act, proposing to initiate reassessment proceeding for the Assessment Year 2020-21. The annexure to that notice contains the summary of information on which such proceedings were proposed to be initiated. It reads as below :

"As per information flagged under Risk Management strategy(RMS) formulated by Central Board of Direct Taxes (CBDT), it has been noticed that you have supplied goods /services of Rs. 73968000/-during financial year 2019-20 (relevant to assessment year 2020-21) to M/s Everett Infra and Engineering Equipments Private Limited