ORDER :

(Sushrut Arvind Dharmadhikari, J.)

The present writ petition under Article 226 of the Constitution of India has been filed challenging the order dated 25.03.2022 passed under Section 148(A)(d) of the Income Tax Act, 1961 (hereinafter referred to as the 'Act' for brevity) and notice dated 27.03.2022 (Annexure P/4) issued under Section 148 of the Act.

2. The brief facts of the case are that the petitioner seeks to challenge the legality, validity and propriety of the notice dated 27.03.2022 issued under Section 148 of the Act seeking to reopen the assessment for the Assessment Year 2018-19 which is based on the order dated 25.03.2022 under Section 148(A)(d) of the Act issued by the respondent No.1. Both, the order and the notice are illegal, without jurisdiction, arbitrary, in violation of the principles of natural justice.

3. Learned counsel for the petitioner contended that despite absence of any information suggesting that income chargeable to tax has escaped assessment, the impugned order under Section 148A(d) has been passed resulting in issuance of notice under Section 148 of the Act. He further argued that without taking into account the reply submitted by the petitioner/a