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2022 Supreme(Jhk) 288

APARESH KUMAR SINGH, DEEPAK ROSHAN
Jindal Forgings – Appellant
Versus
Income Tax Department through Principal Commissioner of Income-Tax, Jamshedpur – Respondent


Advocates:
Advocate Appeared:
For the Appellant : Mr. Kumar Vaibhav, Adv.
For the Respondents: Mr. Rahul Lamba, Adv.

JUDGMENT :

Deepak Roshan, J.

The instant application has been preferred by the petitioner praying therein for quashing of the order as contained in letter dated 31.3.2022 (Annexure-3) passed under Section 148A (d) of the Income Tax Act, 1961 (hereinafter referred to as ‘Act’) whereby it has been ordered that the case of the assessee is a fit case for issuance of notice under Section 148 of the Act for the Assessment Year 2018-19. The petitioner has further prayed for quashing of the entire reassessment proceeding for the Assessment Year 2018-19 including the notice under Section 148A(b) of the Act dated 25.3.2022 (Annexure-2) and also notice under Section 148 of the Act dated 31.3.2022 (Annexure-4).

2. The facts of the case lie in a narrow compass. The petitioner had filed its return of income for the Assessment Year 2018-19, on 25.09.2018. The books of the petitioner were duly audited as per Section 44AB of the Act. On 25.3.2022, a notice under clause (b) of Section 148A of the Act was issued to the petitioner calling upon the petitioner to show- cause as to why notice under Section 148 of the Act be not issued for the reasons stated in annexure to the notice dated 25.3.2022. In this

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