Lakhendra Kumar Raushan Lakhendra Kumar Roushan v. PCIT (2024) 296 Taxman 526 /336 CTR 186/ 467 ITR 549(Patna)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained investments-Notice not disclosing the additions to be made-Matter remanded.[S. 69A, 148A(b), 148A(d), Art. 226]

Held that that there was no specific documents based on which allegation of escaped income was raised. Except for description of unexplained investment with respect to land and vehicle and amount of escaped income proposed, nothing else was stated. As  sufficient material regarding assets on which investments were alleged to have been made were not disclosed in notice under section 148A(b)  and also, a corrigendum containing specification with respect to unexplained investments was issued by department more than two months after order under section 148A(d) was passed which vitiated order. Order under section 148A(d) of the Act is quashed. Directed to pass the order after giving a reasonable opportunity to the appellant.