JUDGMENT : P.C.: 1. By instituting this writ petition dated 28th March, 2022, the petitioner mounts a challenge to the constitutional validity of several provisions of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 (hereafter “the Act”, for short). Incidentally, the trigger for this writ petition appears to be a show-cause notice dated 12th March, 2022 issued by the respondent no.1 in relation to proceedings under section 10 of the 2015 Act, calling upon the petitioner to explain why the amount of Rs.109,42,35,012/- should not be added as income of the petitioner under the relevant provisions of the Act. The petitioner was given time till 17th March, 2022 to furnish his explanation. 2. It is not in dispute that responding to the aforesaid show-cause notice, the petitioner has filed a representation dated March 23, 2022, wherein he has objected to the jurisdiction of the respondent no.1 to issue the impugned notice on multiple grounds. 3. Although Mr. Dada, learned senior counsel appearing for the petitioner has sought to impress upon us that the impugned showcause notice is one issued wholly without jurisdiction and the Court ought to interfere even before the respondent no.1 passes an order on the representation of the petitioner, we need not either refer to the objections raised by the petitioner in his representation in any great detail or deal with the submissions advanced by Mr. Dada, having regard to the order that we propose to pass on this writ petition while disposing of the same based on the request that the petitioner made to the respondent no.1 vide the penultimate paragraph of such representation. Therein, the petitioner requested the respondent no.1 to allow him a hearing on the preliminary objections as raised questioning the jurisdiction of the respondent no.1 to issue the impugned notice and to dispose of the same by passing a speaking order so as to allow the petitioner reasonable time to challenge such order before the appropriate forum including the High Court. 4. We are informed by Ms. Susan Linhares, Standing Counsel appearing for the respondent no.1 that he is inclined to grant the petitioner a personal hearing tomorrow at 3.00 p.m., as well as pass a speaking order dealing with the objections raised by the petitioner in the aforesaid representation. 5. Mr. 4. We are informed by Ms. Susan Linhares, Standing Counsel appearing for the respondent no.1 that he is inclined to grant the petitioner a personal hearing tomorrow at 3.00 p.m., as well as pass a speaking order dealing with the objections raised by the petitioner in the aforesaid representation. 5. Mr. Dada has, at this stage, submitted that if an order is passed by the respondent no.1 on the representation of the petitioner adverse to his interest, the same may not be acted upon immediately and the petitioner ought to be granted at least a fortnight’s time to reply to the show-cause notice on its merits. 6. Having heard learned counsel for the parties, this writ petition stands disposed of with a direction upon the respondent no.1 to hear the petitioner tomorrow at 3.00 p.m. and pass an appropriate reasoned order, in accordance with law, on the objections of the petitioner in relation to the jurisdiction of the respondent no.1 to issue the impugned notice. All contentions on the point of jurisdiction as well as on merits are left open. 7. We make it clear that no separate notice is required to be served on the petitioner since this order is made in the presence of his advocate-on-record, who shall communicate the time when the respondent no.1 intends to hear the petitioner. 8. We grant the petitioner a fortnight’s time, as prayed for, to make further submissions on merits if at all the objections to the jurisdictional issue raised by him are spurned by the respondent no.1. Since on Mr. Dada's prayer we have directed the respondent no.1 to extend to the petitioner opportunity to make his submissions on merits, the period of limitation to pass the requisite order on merits would stand suitably extended so that the relevant order does not get barred by any law of limitation, subject of course to the objections taken in the representation with regard to expiry of limitation to issue the impugned notice in view of applicability of the provisions of the Act. 9. No costs.