(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.) THE assessee has given a rejoinder to the affidavit -in -reply filed by the respondent. In the said rejoinder, the assessee has reiterated the statements made in the petition and in addition to that, it was also pointed out that: