(1.) This application under Article 226 of the Constitution of India is at the instance of an assessee under the Income Tax Act, 1961 [ the Act ] and in this application, the assessee has challenged a notice under Section 148 of the Act and the subsequent reassessment order passed by the Assessing Officer consequent to such notice.
(2.) The case made out by the writ-petitioner may be summarized thus:
(3.) This petition is opposed by the respondent by filing affidavit-in-reply and the defence taken by the respondent may be summed up thus: