20.01.2026 Item No.19 (DL)

Court No.551 AJ.

IN THE HIGH COURT AT CALCUTTA CONSTITUTIONAL WRIT JURISDICTION W.P.A. 20687 of 2025 IVL Dhunseri Petrochem Industries Private Limited -Vs-

Union of India & Ors.

Mr. Pratyush Jhunjhunwala, Ms. Sruti Datta, Ms. Sakshi Singhi. …for the petitioner.

Mr. Aryak Dutt, Mr. Amit Sharma.

….for the respondents.

1. Affidavit of service filed on behalf of the petitioner be kept with the record.

2. This writ petition mounts challenge to a notice issued under Section 148 of the Income Tax Act, 1961 (in short ‘the said Act of 1961’) whereby proceedings for reassessment of the petitioner’s income for the assessment year

2021-22 have been initiated.

3. Mr. Jhunjhunwala, learned Advocate appearing for the petitioner submits that the impugned notice has been issued without there being any information suggesting escapement of income from assessment which is a mandatory 1961. Mr. Jhunjhunwala submits that by issuing such notice, the Assessing Officer has committed a jurisdictional error. It is further submitted that upon receipt of the said notice, the petitioner wrote to the Assessing Officer asking for the information which formed the basis of issuance of the said not