ORDER

In this petition, the petitioner seeks the following reliefs:-

a) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the directions under section 144A of the Act issued by the Respondent No.2, for the assessment year 2020-21, communicated to the petitioner vide letter dated 20.12.2023 issued by Respondent No.1, bearing DIN & Letter No.ITBA/AST/F/17/2023-24/1058940420(1)

herein marked as Annexure- A.

b) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the assessment order dated 23.12.2023 passed under section 143(3) r.w.s 260 r.w.s 144B of the Act for the assessment year 2020-21 passed by the Respondent No.1 bearing DIN No.ITBA/AST/S/143(3)/2023-24/1059031856(1) herein marked as Annexure - B1.

c) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the computation sheet dated 23.12.2023 issued by the Respondent No.1 for the assessment year 2020-21 bearing DIN & Document No.ITBA/AST/S/88/2023-24/1059031873(1)

herein marked as Annexure-B2.

d) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the notice of demand dated 23.12.2023 issued under section 156 of the Act by the Respondent No.1 for the assessment year 2020-21 bearing DIN & Notice No. ITBA/AST/S/156/2023-24/1059031874(1) herein marked as Annexure - B3.

e) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 23.12.2023 issued under section 274 r.w.s 270A of the Act by the Respondent No.1 of the assessment year 2020-21 bearing DIN No.ITBA/PNL/S/270A/2023-

24/1059031871(1) herein marked as Annexure - B4.

f) Issue a writ of Certiorari or direction in the nature of a writ of certiorari quashing the penalty notice dated 23.12.2023 issued under section 274 r.w.s 271AAC(1) of the Act by the Respondent No.1 of the assessment year 2020-21 bearing DIN No.ITBA/PNL/ S/271AAC(1)/2023-24/1059031872(1) herein marked as Annexure - B5.

g) And pass such other orders as this Hon'ble Court deems fit and proper in the interest of justice and equity."

2. Heard the learned Senior Counsel for the petitioner and perused the material on record.

3. In addition to reiterating the various contentions urged in the memorandum of petition and referring to the material on record, learned Senior Counsel for the petitioner invited my attention to the letter dated 13.12.2023 issued by the first respondent to the second respondent - Joint Commissioner of Income Tax calling upon the second respondent to issue directions pursuant to the application filed by the petitioner under Section

144A of the Income Tax Act, 1961 (for short 'the Act'). It is submitted that in pursuance of the same, the second respondent has proceeded to issue the impugned directions at Annexure-'A' dated 20.12.2023 which are cryptic, laconic and non-speaking and without application of mind and without adverting to the various contentions and submissions or the material on record available by the petitioner and as such, the impugned directions at Annexure-'A' are not in conformity with the parameters contained in Section 144A of the Act and the same are violative of the principles of natural justice and deserves to be quashed. It is submitted that based on the aforesaid directions issued by the second respondent under Section 144A of the Act, the first respondent has proceeded to pass the impugned order which also deserves to be quashed along with all further proceedings pursuant thereto and the matter remitted back to the second respondent and thereafter, to the first respondent for reconsideration afresh in accordance with law. 4. Per contra, learned counsel for the respondents would support the impugned directions, orders and proceedings and submit that there is no merit in the petition and the same is liable to be dismissed.

5. Perusal of the material on record, in particular, the impugned directions at Annexure-'A' dated 20.12.2023 will clea