The heading of section 148A of the Income-tax Act, 1961, itself provides for conducting of enquiry and providing an opportunity before issuance of notice under section 148. Section 148A(b) begins with “provide an opportunity of being heard to the assessee”. Hearing does not mean filing a reply to the show-cause notice. If the provision of this section contemplates the opportunity of being heard, it has to be construed as a personal hearing. Therefore, there was no substance in the submission of the Department that an opportunity of being heard to the assessee contemplated under section 148A(b) does not necessarily mean a personal hearing. Held, that, admittedly, no opportunity of being heard personally was given to the assessee. Hence, the notice under section 148A was not valid.(AY. 2019-20)