ORDER

1.In this Writ Petition, the Petitioner has challenged the impugned order dated 29.07.2022 passed under Section 148A(d) of the Income Tax Act, 1961 and the impugned notice dated 29.07.2022 issued under Section 148 of the Act for the Assessment Year 2014-2015 under the new regime which came into effect from 01.04.2021. BRIEF FACTS OF THE CASE:-

2.The impugned order dated 29.07.2022 has been passed in the background of a Notice dated 02.06.2022 issued under Section 148A(b) of the Act, in the light of the decision of the Hon’ble Supreme Court in Union of India Vs. Ashish Agarwal, (2023) 1 SCC 617.

3.The impugned order dated 29.07.2022 passed under Section 148A(d) of the Act proposes to issue the impugned Notice dated 29.07.2022 under Section 148 for the Assessment Year 2014-2015 on the grounds of (i) limitation and (ii) change of opinion.

4.Reading of the impugned order indicates that the Respondent has examined the petitioner’s reply dated 20.06.2022 to the Notice dated 02.06.2022 issued under Section 148A(b) of the Act. The conclusions arrived at by the respondent for justifying the impugned order and the issuance of consequential Section 148 Notice both dated 29.07.2022, are as f