Allowing the petition the Court held that the Assessing Officer passed order under section 148A(d) without consideration of reply made by assessee and issued notice under section 148 of the Act since there was no consideration of reply made by assessee, order and notice was set aside with a direction to Assessing Officer to reconsider reply and advert to same while passing fresh order under section 148A(d) of the Act. Matter remanded.
Flipkart (P.) Ltd. v. ITO(IT) (2023) 294 Taxman 300 (Karn.)(HC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Share application money-Order passed without considering the reply-Order is set aside-Matter is remanded. [S. 148A(b), 148A(d), Art. 226]