The Assessee challenged the notice issued u/s 148 of the Act on various grounds before the High Court by filing the writ partition . The High Court dismissed the Petition stating that they were not inclined to entertain this petition. On SLP before the Supreme Court , the Supreme Court set aside the impugned order back to the High Court to pass a speaking order on all the grounds raised in the Petition and decide a fresh on their merits . ( CA Nos 220 to 2203 of 2022 March 28, 2022
Vishal Ashwin Patel v. ACIT [2022] 136 taxmann.com 372 / www.itatonline.org (SC) Editorial: Reversed Vishal Ashwin Patel v. ACIT (WP Nos. 3209/2019, 3150/2019, 3208/2019 and 3137/2019 (Bom)(HC) dated January 11, 2022.
S. 147 Reassessment – Notice – Writ Petition – High Court dismisses the Petition – Not a reasoned order – Order set aside to High Court and decide a fresh on their merits . [S. 148 ,Art , 226 ]