1. This writ petition, along with other writ petitions listed today, have been filed by various assessees to challenge the initiation of assessment proceedings under S.148 of the Income - tax Act, 1961 (the Act) for different assessment years. All notices in these petitions for initiation of assessment proceedings have been issued after April 1, 2021.

2. Since substantial questions of law were involved, interim protection has been granted. The Revenue has also filed reply in many petitions and many petitioners have also filed rejoinder. Since the issues were identical, we did not insist on the Revenue filing a reply in each of the petitions.

3. The cause of action of dispute arising in all these writ petitions purely being legal, i. e., on the validity of the assessment proceedings initiated against the assessees after April 1, 2021 under the provisions of the Ac