ITO v. Asamannoor Service Co-operative Bank Ltd [2024] 160 taxmann.com 681 / (2025) 482 ITR 305 (Ker)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Failure to provide personal hearing-Violation of statutory condition and principles of natural justice-Order of single judge affirmed. [S. 147, 148, 148A(b), 148A(d), Art. 226]

Dismissing the appeal of the revenue against single judge the Court held that  the express provisions of section 148A contemplated that the assessee should be granted an opportunity of being heard and that opportunity to be effective should include a right to a personal hearing as well. The order passed in the writ petition quashing the notice issued under section 148 for reopening the assessment under section 147 for the assessment year 2019-2020 was not interfered with.(AY. 2019-20)

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