Heard Mr. R.S.Mishra, learned counsel for the petitioner.
Ms. K.Gurung, learned counsel vice Dr. N.Mozika, learned DSGI
is present on behalf of the respondent No. 1, and Mr. K. Jain, learned
counsel is present today on behalf of the respondents No. 2-5, as such,
notice is complete on all the respondents.
The grievance of the writ petitioner is that the assessment order
under section 147 r/w section 144, 144 B of the Income Tax Act, was
passed on 26-03-2022, where proceedings was initiated for reopening of
the case of the petitioner. It is submitted that the said assessment order is
without any jurisdiction, inasmuch as, the notification notifying the scope
of the scheme for assessment, re-assessment under section 3 thereof, came
into force only on 29-03-2022. He further submitted that though there is
provision for appeal, but as the challenge is to the jurisdiction of the
respondents No. 2-5 in passing a similar order, this writ petition has been
preferred.
