The present writ petition under Article 226 of the Constitution of India

has been filed challenging the order dated 25.03.2022 passed under Section

148(A)(d) of the Income Tax Act, 1961 (hereinafter referred to as the 'Act' for

brevity) and notice dated 27.03.2022 (Annexure P/4) issued under Section 148

of the Act.

1

Signed by: SREEVIDYA

Signing time: 12/6/2023

3:02:04 PM

Signature Not Verified

2. The brief facts of the case are that the petitioner seeks to challenge

the legality, validity and propriety of the notice dated 27.03.2022 issued under

Section 148 of the Act seeking to reopen the assessment for the Assessment

Year 2018-19 which is based on the order dated 25.03.2022 under Section

148(A)(d) of the Act issued by the respondent No.1. Both, the order and the

notice are illegal, without jurisdiction, arbitrary, in violation of the principles of

natural justice.

3. Learned counsel for the petitioner contended that despite absence

of any information suggesting that income chargeable to tax has escaped

assessment, the impugned order under Section 148A(d) has been passed

resulting in issuance of notice under Section 148 of the Act. He further argued

that without taking into account