KAILASH KEDIA Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) In all these writ petitions, the challenge is to:

(2.) While issuing notice in all these writ petitions, interim orders were passed restraining the Respondent/Income Tax Department ("Department") from taking coercive action against the Petitioners.

(3.) During the pendency of the present petitions, a coordinate Division Bench (DB) of this Court delivered two judgments. One is the judgment dtd. 6/9/2022 delivered by a DB of which one of us (M.S. Raman, J.) was a member in W.P.(C) No.15102 of 2022 (Auroglobal Comtrade Private Limited v. The Chairman, Central Board of Direct Taxes and others) and the other by the same DB on 27 th September, 2022 in W.P.(C) No.17176 of 2022 (Stewart Science College v. Income Tax Officer, Ward-1 (1), both of which declined to accept similar challenge to the notices under Sec. 148-A(1)(b) of the Act as well as the consequential order under Sec. 148-A(1)(d) of the Act by holding that the Petitioners/Assessees in those cases would have a full opportunity of urging all the grounds of challenge at the stage of challenging the consequential order in the reassessment proceedings consequent upon the notice under Sec. 148 of Act.