2 The respondent had issued a notice dated 28.03.2007 under Section 148 of the Income Tax Act, reopening the assessment of M/s.M.Ct.M. Corporation Private Limited for A.Y.2000-2001. In response to the same, the appellant had sent a reply dated 05.04.2007 stating that for A.Y.2000-2001, the Company was not in existence, for which, the respondent had sent communication on 16.05.2007 providing reasons for reopening of assessment for the Assessment Year 2000-2001. On receiving the above communications, the appellant on 31.05.2007 sent his objections for reopening by the Assessing Officer. The Assessing Officer had sent a letter on 18.07.2007 rejecting the objections raised by the appellant/assessee. The appellant, challenging the notice issued under Section 148 of the Income Tax Act and also the rejection order of the Assessing Officer dated 18.07.2007, had filed the writ petition in W.P.No.26276 of 2007. The learned single Judge, after considering the submissions made on both the parties, passed the order dated 26.07.2019, wherein, liberty was given to the appellant to raise further objections before the Assessing Officer to the notice dated 28.03.2007 issued under Section 148 of the Income Tax Act and on receipt of such objections, the Assessing Officer was directed to deal with it in accordance with law, and after giving due opportunity to the appellant, final decision has to be taken. Challenging the above order passed by the Writ Court dated 26.07.2019, the assessee has filed this writ appeal.
