The Assessing Officer issued notice under section 148 and initiated reassessment proceedings against assessee  on the ground that the assessee was a beneficiary of an accommodation entry provided in form of bogus loans.  The assessee challenged the proceedings by filing writ petition. Allowing the petition the Court held  that since search and seizure action under section 132 was not carried out against assessee such action was carried out against a third party  and the  assessee was not given opportunity of hearing. Accordingly the order passed under section 148A(d) and consequential notice issued under section 148  was also quashed and set aside. (AY. 2019-20)