The Assessing Officer passed an order under section 148A(d) alleging that the assessee had failed to demonstrate that certain receipts had been fully disclosed. The High Court found that some allegations were raised for the first time in the said order, thereby denying the assessee an opportunity to respond. As regards other receipts, the assessee had provided a detailed explanation in its reply to the notice under section 148A(b). The Court observed that the Assessing Officer, without giving reasons for not accepting the explanation, merely made a bald statement that the assessee had failed to demonstrate disclosure. The Court held that the order was passed without application of mind. Consequently, the sanction granted under section 151 and the consequent notice issued under section 148 were also quashed. (AY. 2019-20)