(1.) The petitioner, through the medium of present writ petition, seeks the following reliefs:
(2.) The impugned proceedings relate to Financial Year 2012-13, relevant to Assessment Year 2013-14. The record reveals that an initial notice under Sec. 148 of the Act for Assessment Year 2013-14 was issued to the petitioner on 31/5/2021. Subsequently, pursuant to the judgment of the Hon'ble Supreme Court in "Union of India v. Ashish Agarwal", Civil Appeal No. 3005 of 2022, dtd. 4/5/2022, the Assessing Officer (respondent No. 4) issued a communication dtd. 24/5/2022, providing information suggesting that some income may have escaped assessment under Sec. 147 of the Act and asked the petitioner to show cause as to why an order under Sec. 148A(d) should not be passed.
(3.) In the said show cause notice alleged escapement of income to the extent of Rs.1,30,00,000.00 and provided fifteen days' time from the date of receipt of the notice to submit a response, and the compliance was required to be made on or before 8/6/2022. However, no response was filed by the petitioner to the aforesaid show cause notice. Consequently, the Assessing Officer passed an order dtd. 25/7/2022 under Sec. 148A(d), holding the case fit for issuance of a notice under Sec. 148, and issued the consequential notice dtd. 26/7/2022.