9911796707
TMI Blog2023 (5) TMI 366X X X X Extracts X X X X X X X X Extracts X X X X ..... wal, Advocates For the Opposite Parties : Mr. Sidharth Sankar Mohapatra, Senior Standing Counsel for Income Tax Department ORDER DR. S. MURALIDHAR, CJ. 1. The memo of appearance filed by Mr. Sidharth Sankar Mohapatra, learned Senior Standing Counsel for Income Tax Department-Opposite Parties is taken on record. 2. As regards the challenge to an order passed under Section 148A(d) of the Income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of another Bench of the Supreme Court of India, the composition of which is different from the Bench which heard the aforementioned case in Anshul Jain (supra), where another order dated 2nd June, 2022 of the High Court of Punjab and Haryana in CWP No.10073 of 2022 (Red Chilli International Sales v. Income Tax Officer) was challenged. In the said SLP (C) No.86 of 2023, the following order was pass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the writ petition would not be maintainable in view of the alternative remedy, clarify that this issue would be examined in depth by the High Court if and when it arise for consideration. We do deem it open to examine this issue in the present case after having examined the notice under Section 148A (b) including the annexure thereto, the reply filed by the petitioner and the order under Section 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 148A(d) of the Act. 6. Learned counsel for the Petitioner urges that apart from the ground that the notice under Section 148A(b) of the Act was time barred, it is also vitiated by what he terms as 'mere change of opinion' by the Assessing Officer. 7. Needless to say, it will be open to the Petitioner to raise all grounds available to the Petitioner in accordance with law, including the above gr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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