Dismissing the petition, the Court held that the assessee was granted time up to April 14, 2023 and the order was passed only on April 21, 2023. There was no question of any remand being made for the purpose of earing. The order issued under section 148A(d) was not conclusive. The consequent notice under section 148 having already been issued the assessee would be entitled to raise all contentions in reply to that notice, if it had not concluded. (AY.)
Naubind Singh v. PCIT (2025) 474 ITR 193 (Patna)(HC) Editorial : SLP of assessee dismissed, Naubind Singh v Pr. CIT (2025) 474 ITR 196 (SC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Failure to issue notice-Order under section 148A(d) was not conclusive-Writ petition was dismissed. [S 147, 148, 148A(b), 148A(d), Art.226]