Writ Jurisdiction on Section 148A(d) Orders Requires Exhaustion of Remedies

Laxminarayan Patidar Vs ITO (Madhya Pradesh High Court) Madhya Pradesh High Court dismissed a writ petition filed by Laxminarayan Patidar challenging an order under Section 148A(d) and a subsequent notice under Section 148 of the Income Tax Act, 1961, related to the reopening of assessment for AY 2018-19. The petitioner argued that the order and notice were arbitrary, without jurisdiction, and in violation of natural justice, as no proper opportunity for a hearing was given. Additionally, it was contended that the Assessing Officer failed to consider the petitioner’s response before passing ...