Assessing Officer issued on assessee a notice under section 148A(b) calling upon it to show cause as to why a notice under section 148 should not be issued. Assessee filed reply to show cause notice  Assessing Officer without affording assessee an opportunity of heard passed order in terms of section 148A(d) and consequently issued notice under section 148. On writ the  Revenue contended before High Court that so long as show cause notice envisaged under section 148A was issued to assessee, opportunity of being heard was to be seen as provided. Allowing the petition the Court held that   service of show cause notice under section 148A(b) is only first step in process of extending an opportunity of being heard to assessee and thus, service of show cause notice by itself did not tantamount to a discharge of obligation to provide assessee with an opportunity of being heard. Notice is set a side and directed to pass speaking order after giving a reasonable opportunity of being heard. On appeal by Revenue dismissing the appeal the Court held that opportunity to be effective must include a right to a personal hearing as well. (AY. 2019-20)