Allowing the petition the Court held that the notice and the order were cryptic as was evident from the fact that the information culled out from the assessee’s own return and records (namely form 10DB, goods and services tax return, form 26AS) had been used to issue notice under section 148A(b) without mentioning what was wrong in those transactions, what were the apprehensions of the Assessing Officer and what were the points on which clarification was required. Expenditure incurred by the assessee on salaries, payment of professional fees and purchases could not amount to income having escaped assessment without there being any allegation that the employees or professionals to whom salaries and fees had been paid were dummies or fictitious entities. Reassessment was sought to be initiated merely for verification. Even if the reassessment was being done for verification, in accordance with Explanation 1 to section 148, the Assessing Officer should have conducted an enquiry in accordance with section 148A(a) with respect to the information and scrutinised the contentions and submissions of the assessee before passing an order under section 148A(d) of the Act. Court also held that the non-sharing of the information was violative of the principle of natural justice. The mandate of section 148A(c) had been violated since the order under section 148A(d) had been passed without considering the detailed reply filed by the assessee.  The order passed under section 148A(d) and the notice issued under section 148 were quashed and the matter was remanded back to the Assessing Officer to pass a reasoned order in accordance with law after considering the assessee’s reply. Referred  Sabh Infrastructure Ltd. v. ACIT (2017) 398 ITR 198 (Delhi)(HC).