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2022 (5) TMI 1288 - HC - Income TaxReopening of assessment u/s 147 - scope of amended procedure u/s 148A - disallowing the loss so computed and reducing the same from the business loss of the assessee entitled to be carried forward under Section 72 for set off in future - HELD THAT:- This Court finds that the Petitioner has not brought on record anything to prove that the impugned notice issued shall be governed by the amended procedure under Section 148A of the Act. This Court is also of the view that Petitioner is basically challenging the impugned order on merits. The Supreme Court in Commissioner of Income Tax and Ors. Vs. Chhabil Das Agarwal [2013 (8) TMI 458 - SUPREME COURT] has held that as the Income Tax Act, 1961 provides complete machinery for assessment/reassessment of tax, assessee is not permitted to abandon that machinery and invoke jurisdiction of High Court under Article 226. This Court is further of the view that the present case does not fall under the exceptional grounds on which a writ petition is maintainable at the interim stage in tax matters.
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