(1.) By this writ petition invoking our jurisdiction under Article 226 of the Constitution of India, the Petitioner impugns Notice dtd. 22/3/2004 issued by the Respondent No.1 - Deputy Commissioner of Income Tax, Circle 2(2), Mumbai, under Sec. 148 of the Income Tax Act, 1961 (hereinafter referred as "the Act ") alongwith order dtd. 4/3/2005 dismissing the Petitioner 's objections to reopening of assessment for the Assessment Year 1997-98.
(2.) Rule. By consent of the parties, Rule is made returnable forthwith and the petition is heard finally.
(3.) The primary contentions raised in the writ petition are stated as under :