[2025:RJ-JP:33218-DB] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR D.B. Civil Writ Petition No. 10651/2025 Kamal Khandelwal (Ay 2018-19) S/o Shri Amba Prasad Khandelwal, Aged About 45 Years, R/o D-86, Pawan Path, Opposite Gurudwara, Vaishali Nagar, Jaipur, Rajasthan - 302021. ----Petitioner Versus 1. Deputy Commissioner Of Income Tax, Office Of Deputy Commissioner Of Income Tax, Central Circle 4, Room No. 416, 4th Floor, Jeevan Nidhi 2, Lic Building, Ambedkar Circle, Jaipur, Rajasthan - 302005. 2. Director General Of Income Tax (Investigation), 2nd Floor, NCR Building, Statue Circle, Jaipur, Rajasthan - 302005. ----Respondents For Petitioner(s) : Mr. Vedant Agarwal, Adv. For Respondent(s) : Mr. Siddharth Bapna, Adv. Mr. Rahul Kumar, Adv. Mr. Meyhul Mittal, Adv. HON'BLE MR. JUSTICE SANJEEV PRAKASH SHARMA HON'BLE MR. JUSTICE SANJEET PUROHIT Order 22/08/2025 1. The challenge is to the proceedings initiated against the petitioner based on information received during search proceedings under Section 132 of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act of 1961’). Notice was issued to the petitioner under Section 148 of the Act of 1961 on 20.03.2024 for AY 2018-2019. Thereafter, assessment order has been passed on 14.02.2025. Without availing the statutory remedy available under the Act of 1961, the present petition has been filed assailing the order dated 14.02.2025 along with the notice issued to [2025:RJ-JP:33218-DB] (2 of 2) [CW-10651/2025] petitioner under Section 271AAC(1), 271D and 271E of the Act of 1961. 2. We are of the opinion that the statutory remedy as available under the Act of 1961 cannot be bypassed and while hearing petition under Article 226 of the Constitution of India we have a limited scope of jurisdiction to entertain the cases relating to orders passed under Section 148 of the Act of 1961. At this stage, we are not required to enter into the factual aspects. We do not find that any question of law is required to be examined by us or any jurisdictional issue in the present case leaving it open to take up all grounds as available to him before the Appellate Authority. We are not inclined to entertain the present petition. 3. Accordingly, the present civil writ petition is dismissed. 4. Stay application also stands disposed. 5. All pending application(s), if any, stand disposed of. (SANJEET PUROHIT),J (SANJEEV PRAKASH SHARMA),J HEENA/MAHIMA/11