J U D G M E N T

The petitioner is an assessee under Income Tax Act, 1961 and is aggrieved by Ext.P3 notice issued by the respondents under Sec.148 of the . The challenge was raised by the petitioner mainly on the ground that, despite the fact that Sec.148A of the Income Tax Act, contemplates for a prior notice to the petitioner/assessee before issuing a notice under Sec.148, such procedure has not been adopted in this case. It was in these circumstances, this writ petition was filed, seeking following reliefs:-

“For these and other grounds to be urged at the time of hearing, it is most humbly prayed that this Hon’ble Court be pleased to call for records leading to Ext. P1 to Ext. P3 and:

i. issue a writ of certiorari or such other appropriate writ, direction or order and quash Exhibit P3 notice dated 29.03.2025 issued by the Respondent; and ii. to grant such other and incidental reliefs as this Hon’ble court may deem fit, just and nec