Allowing the appeal against the single Judge order, the Court held that   it is the duty of the Assessing Officer to consider the explanation of the assessee substantiating the alleged transaction and give reasons as to why it was not acceptable. The Assessing Officer had only stated that the assessee had failed to substantiate the alleged amount of escaped income of Rs. 25 lakhs was a genuine transaction. The order passed under section 148A(d) is a non-speaking order without application of mind. It also revealed that the Assessing Officer had no material to controvert the explanation offered by the assessee that the lending entity was non-banking financial company and that the loan was taken in the assessment year 2019-20 and repaid along with interest in the same year and this had been substantiated by the assessee by producing the ledger copy of the loan account. Reassessment notice is quashed and all other proceedings are set aside.  (AY. 2019-20)