Petitioner is engaged in business of civil construction was issued notice under section 148A(b) to show cause as to why notice under section 148 for reopening should not be issued. Petitioner had submitted detailed reply raising various objections such as limitation, change of opinion, etc., along with details pertaining to capital gains tax computation paid on sale of property. The Assessing Officer held that petitioner’s submissions and found unacceptable, therefore, order under section 148A(d) and notice under section 148 were issued  the Assessing Officer also observed that the  petitioner’s submissions would require further verification. On writ the  allowing the petition the Court held that   no conclusion could had been reached by Department that petitioner’s case was fit for issuance of notice under section 148 and since petitioner’s objections were dealt with in a very mechanical manner, order and notice were  set aside and matter was  remanded back to pass a fresh order in accordance with law after giving an opportunity of personal hearing.  (AY. 2016-17)