Chotanagpur Diocesan Trust Association v. UOI (2024) 464 ITR 748 (Jharkhand)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Assessee must be given opportunity to be heard-Notice and order disposing the objection is quashed and set aside.[S. 148, 148A(b), 148A(d),Art. 226]

Allowing the petition the Court  held, that the respondents after issuance of the notice under section 148A(b) of the Act, had started gathering information and supporting documents ; however, even after obtaining the information and supporting documents, they did not disclose such information and supporting documents to the assessee. Consequently, the order dated March 22, 2023 passed under section 148A(d) of the Act, 1961 for the assessment year 2019-20 and also the subsequent notice dated March 22, 2023 issued under section 148 of the Act, had to be quashed and set aside.(AY.2019-20)