Rakesh Beniyal v. ITO (Assessment) (2024) 299 Taxman 409 (Mad.)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credits-Bank account was opened without his knowledge-Disputed questions of fact-Writ petition is dismissed. [S. 148, 148A(b), 148A(d), Art. 226]

The Assessing Officer passed the reassessment order. The assessee filed writ petition   and contended that a bank account was opened in his name without his knowledge and that transactions in such account resulted in re-assessment order.  Since fact that a bank account was opened in name of assessee without his knowledge and that transactions in such account resulted in reassessment order were disputed questions of fact which could not be conveniently addressed in proceedings under article 226. Writ petition is dismissed.