Dinesh Verma v. ITO (2023)456 ITR 682/ (2022) 141 taxmann.com 453 (P&H)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Based on facts-Writ is not maintainable. [S. 147, 148A(b), 148A((d), Art. 226]

Dismissing the petition the Court held that  from a bare reading of the notice it could not be axiomatically held that the authority had assumed jurisdiction not vested in it. The correctness of order under section 148A(d) of the Income-tax Act, 1961, was being challenged on a factual premise contending that jurisdiction though vested had been wrongly exercised. Writ petition is dismissed. (AY.2015-16)