Dismissing the petition the Court held that the assessee had made out a baseless and frivolous case that the initial notice under section 148A(b), the order under section 148A(d) and the consequent notice under section 148 related to three assessment years 2016-17, 2017-18 and 2018-19 which was contrary to record. The initial notice under section 148A(b) it had been clearly described that the notice had been issued relating to the financial year 2015-16 relevant to the assess-ment year 2016-17. In the annexure to the notice under section 148A(b) incidentally the Assessing Officer might have recorded some transactions relating to some other financial years, but, considering the annexure as a whole, the initial notice under section 148A(b) had been issued for the assessment year 2016-17 only.Accordingly the initial notice under section 148A(b), the order under section 148A(d) and the notice under section 148 were valid.(AY. 2016-17)
Champa Impex Pvt. Ltd. v. UOI (2024)470 ITR 689 (Cal)(HC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice mentioning for which the notice issued-Transactions recorded of other financial year-Notice valid.[S. 147, 148, 148A(b), 148A(d), Art. 226]
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