O R D E R

1.In this Writ Petition, the Petitioner has challenged the Notice dated 29.07.2022 issued by the under Section 148 of the Act under the new regime and the Order dated 29.07.2022 passed by the respondents under Section 148A(d) of the Act under the regime for the Assessment Year 2017-2018.

2. The Petitioner had not filed a Return of Income for the Assessment Year 2017-2018. Earlier, Notice under Section 148 of the Act under the old regime as in force from 31.03.2021 was issued by the Respondent on 05.04.2021 to the Petitioner for the Assessment Year 2017-2018, which has culminated in the impugned proceedings pursuant to the amendment to the Income Tax Act, 1961 with effect from 01.04.2021.

3. Heard M/s Hema Muralikrishnan, learned counsel for the Petitioner and Mr.Ramasamy, learned Senior Standing Counsel for the Respondents.

4. Have perused the documents and the list of dates and events qua Paragraph No.28 from the decision of the Hon’ble Supreme Court in Union of India Vs. Ashish Agarwal, (2023) 1 SCC 617 and Paragraph Nos.112 and 114 from the decision of the Hon’ble Supreme Court in Union of India Vs. Rajeev Bansal, 2024 SCC Online SC 2993.

5. It will therefore be useful to r