(1.) Rule. Rule made returnable forthwith. By consent of both counsel, Petition taken up for final hearing at the admission stage.
(2.) By this Petition, Petitioner challenges the Notice dtd. 26/3/2019 issued under Sec. 148 of the Income Tax Act, 1961 (the said Act) and the Order dtd. 20/11/2019 disposing Petitioner's objections to the reopening of assessment. Petitioner was Managing Director of a Company and earned income from salary, income from house property and income from other sources. For the assessment year 2012-2013, Petitioner has filed income tax return on 27/7/2012 disclosing the total income of Rs.81,23,933..00 The assessment was completed under Sec. 143(3) of the said Act. In the assessment order dtd. 31/12/2014, the income was assessed at Rs.82,07,933.00.
(3.) Petitioner received impugned notice dtd. 26/3/2019 under Sec. 148 of the said Act informing Petitioner that there were reasons to believe Petitioner's income chargeable to tax for the assessment year 2012-2013 has escaped Assessment within the meaning of Sec. 147 of the said Act. Petitioner was called upon to file return in the prescribed form which Petitioner did. Petitioner was also provided with the reasons to believe for reopening of assessment along with notice dtd. 20/9/2019 under Sec. 142(1) of the said Act. Reasons to believe reads as under: