The AO sought to reopen the assessment of the assessee, who was resident of Uganda, on the basis of information received that the assessee had indulged in transactions of time deposits and mutual fund investments but did not file return of income. The assessee submitted all the related details before the AO. However, the AO passed order u/s. 148A(d) holding that it was a fit case for issuance of notice u/s. 148 of the Act. The assessee challenged the same under Writ. The High Court accepted the contentions of the assessee that all investments were from non-resident (External) accounts and could not be subject of tax in accordance with the provisions of section 10(4) of the Act. Accordingly, the High Court held that impugned order was without jurisdiction.(AY. 2018-19)