Assessee, an individual, was a co-owner who had purchased land jointly with her mother under a sale deed executed in June 2019. Assessee challenged the jurisdictional notice issued under section 148. On writ, the Court held that the assessee’s mother, who was co-owner of the same land, had also been subjected to reopening on identical facts and reopening in her case had already been quashed and set aside by the High Court. Since reopening of assessment in the case of the mother of the assessee, who was co-owner of the land in question, had already been quashed and set aside, the jurisdictional notice issued under section 148, reassessment order passed under section 147 and penalty notice issued under section 271DA were quashed and set aside. (AY. 2020-21)