The Court: This writ petition has been filed against an order dated June
28, 2025, passed under Section 148A(3) of the Income Tax Act, 1961 and the
consequential notice issued on the same date under Section 148 of the said Act
of 1961 in respect of assessment year 2019-20.
Initially a notice under Section 148A (1) of the said Act of 1961 had been
issued to the petitioner thereby calling upon to petitioner to show cause why
proceedings for reassessment of the petitioner’s income for the assessment year
2019-20 should not be initiated on two grounds i.e. – (i) inadmissible claim of
expenses alleging that the expenses whereof deduction was sought pertained to
capital loss and not revenue loss and (ii) inadmissible claim of deduction
alleging that the CSR expenditure could not be claimed by the petitioner as a
deduction under Section 80G of the said Act of 1961.
