AJAY BHANDARI Vs. UNION OF INDIA

JUDGEMENT

(1.) Heard Shri Ankur Agarwal, learned counsel for the petitioner, Shri S.P. Singh, learned Additional Solicitor General of India assisted by Shri Krishna Agarwal, learned Senior Standing Counsel for the respondent/Income Tax Department and Shri Anant Kumar Tiwari, learned Central Government Standing Counsel.

(2.) With the consent of the learned counsel for the parties, this writ petition is being finally heard without calling for a counter affidavit inasmuch as no disputed question of fact is involved in the writ petition. The reliefs sought in the writ petition are reproduced below:

(3.) It has been admitted by the learned counsel for the parties before us that the impugned notice under Sec. 148 of the Income Tax Act, 1961 (hereinafter referred to as the 'Act, 1961') for the assessment year 2014-15 was issued by the respondent no. 3 to the petitioner on 1/4/2021. The "reasons to believe" recorded by the respondent no. 3 for issuing the impugned notice, is as under: