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TMI Blog2022 (4) TMI 596X X X X Extracts X X X X X X X X Extracts X X X X ..... h Chaurasia, Advocates. Respondent Through: Ms. Vibhooti Malhotra, Sr. Standing Counsel with Mr. Shailendra Singh, Jr. Standing Counsel and Mr. Udit Sharma, Advocates. J U D G M E N T MANMOHAN, J (Oral) 1. Present writ petition has been filed challenging the order dated 28th March, 2022 passed by Respondent under Section 148A(d) of the Income Tax Act, 1961 ['the Act'] for the assessment year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the investigation wing which does not have any rational nexus with the petitioner. He states that the information mentioned in the Show Cause Notice pertains to the Assessment Year 2014-15 which has been used to frame reason to believe escapement of income for the Assessment year 2018-19. 4. A perusal of the paper book reveals that in the impugned order dated 28th March, 2022, the respondent has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Supreme Court judgment in Raymond Woollen Mills Ltd. vs. Income-tax Officer, Centre Circle XI, Range Bombay and Ors. (2008) 14 SCC 218, is clearly attracted to the facts of the present case inasmuch as in the said judgment it has been held, "In determining whether commencement of reassessment proceedings was valid it has only to be seen whether there was prima facie some material on the basi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessment of tax, assessee is not permitted to abandon that machinery and invoke jurisdiction of High Court under Article 226. Consequently, the present case does not fall under the exceptional grounds on which a writ petition is maintainable at the interim stage in tax matters. [See: Ghanashyam Mishra And Sons Private Limited Vs. Edelweiss Assetre Construction Company Limited, (2021) 9 SCC 657 an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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