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2025 Supreme(Online)(Del) 48566

Amandeep Singh Proprietor Guru Kripa Enterprises v. Office Of The Assistant Commissioner Of Income Tax Circle 10 (1)


VINOD KUMAR , J. (ORAL)

1. The present writ petition has been filed seeking a writ of Certiorari or Mandamus praying for setting aside a notice dated 30.06.2025 issued under Section 148 of the Income Tax Act, 1961 (in short ‘the Act’), order dated 30.06.2025 under Section 148A (3) of the Act, notice dated 13.06.2025 under Section 148A(1) of the Act and notice dated 29.03.2025 under Section 148A(1) of the Act issued by the respondent-Revenue for the Assessment Year (in short ‘A.Y.’) 2021-22.

2. The case of the petitioner is that he had filed Return of Income on 14.03.2022 declaring an income of Rs.8,53,950/- for the A.Y. 2021-22. On 29.03.2025, the respondent issued a notice under Section 148A (1) for the A.Y. 2021-22 to the petitioner stating that income chargeable to tax has escaped assessment “as per risk management strategy” and alleged that various dummy/shell entities/companies and bank accounts were associated with the petitioner. On 07.04.2025, a reply was filed by the petitioner to the aforesaid notices raising objection that ‘reason to believe’ relied upon by the respondent is a wrong ‘reason to believe’ and that prima-facie no relation of petitioner is established with the

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