Assessing Officer issued a show cause notice under section 148A(b) to assessee for reopening the assessment on the ground that assessee had made bogus purchases from a fictitious entity, ZMEPL. In response, the assessee clarified that it had not incurred any transactions with ZMEPL but with a contractor named ZIEPL. Pursuant thereto, the Assessing Officer conducted a physical verification at the address of said contractor and found that no such entity existed. Thus, he concluded that said contractor was a non-existent bogus entity and passed an order under section 148A(d) and issued a notice under section 148. High Court held that since the conclusion regarding the said contractor being a non-existent bogus entity was never put to assessee in the show-cause notice issued under section 148A(b), it was a violation of the principles of natural justice. Further, since incriminating material was not put to the assessee after closure of original assessment proceedings, the assessee was deprived of an opportunity to explain the existence or otherwise of the contractor; thus, the order under section 148A(d) and notice under section 148 were to be set aside. SLP of revenue dismissed. (AY. 2018-19)