(1.) The challenge in the present writ petition is to the notice dtd. 19/7/2022 issued under Sec. 148 of the Income Tax Act, 1961 as also to the notice issued under Sec. 148A(d) dtd. 15/7/2022 (Annexure P/3 collectively).
(2.) The primary challenge to the said notice was the non-supply of the necessary information and the material documents on the basis of which the notices under Sec. 148 and the notice under Sec. 148A(d) has been issued. The specific contention raised by the counsel for the petitioner was that after the notice under Sec. 148A(b) was received by the petitioner on 26/5/2022, the petitioner gave a reply to the same on 6/6/2022 and thereafter an additional reply was further submitted on 8/6/2022. According to the petitioner, in the additional reply that he had submitted on the 8 th of June, he had raised a specific claim for providing of the necessary information and material documents which forms the basis for issuance of the notice was issued.
(3.) Learned counsel for the petitioner submitted that the information that he had sought for was those informations which is referred to in the notice as well, on the basis of which the notice under Sec. 148A(b) has been issued. The nature of documents and informations sought for are: