The assessee did not file its reply to notice issued u/s. 148A (b) of the Act for A.Y. 2018-19 even though 3 adjournments were granted. Therefore, the AO passed order u/s. 148A (d) on account of default of the assessee in not submitting the reply to the show cause notice considering it was a fit case to issue notice under section 148 of the Act. The AO also passed consequential assessment order. The assessee challenged under writ the order passed u/s. 148A (d) as it was non-speaking and also the assessment order passed u/s 147. The High Court held that even in an ex parte proceedings, the authority has to record reasons for coming to a conclusion as to why the case has been taken out for re-opening of the assessment. The matter was restored to the AO at the stage of notice u/s. 148(b) of the Act but the assessee was precluded from raising issue related to limitation.(AY. 2018-19)