The show cause notice was issued under Section 148A(b) of the Act to the Petitioner and did not contain any allegation of escapement of income nor was the petitioner ever asked to explain the source of funds as alleged in notice issued under Section 148A(d). However, the Impugned order was passed on a completely different ground altogether. On writ allowing the petition the Court held that if the foundational allegation is missing in the notice issued under Section 148A(b) of the Act, the same cannot be incorporated by issuing a supplementary notice. The show cause notice issued under Section 148A(b) of the Act as well as the order passed under Section 148A(d) of the Act and the notice issued under Section 148 of the Act for the assessment year 2018-19 are quashed. Liberty granted to Respondents/Revenue to take further steps in the matter if the law so permits. If and when such steps are taken and if the Petitioner has a grievance, it shall be at liberty to take its remedies in accordance with law. Mahasthan DI Hati Pvt. Ltd.  v. Dy. CIT (2022) 448 ITR 667 (Delhi)(HC), distinguished. (AY. 2018-19)