Assessing Officer issued a show cause notice under Section 148A(1) alleging escapement of income based on flagged high-risk transactions and a GST show cause notice proposing registration cancellation for ineligible ITC. GST registration was cancelled, but on appeal, the Appellate Authority restored it, noting denial of hearing, non-consideration of assessee’s reply, absence of adjudication to establish fraudulent ITC, and that business was supported by returns and banking records. Despite this, the Assessing Officer issued a notice under Section 148. On writ, the Court held that since reopening of assessment by resorting to the provisions of Section 148A and Section 148 emanated from a cancellation order passed by GST Authorities which had been set aside by the Appellate Authority, and apart from this, there was no other material which was in possession of the Assessing Officer, which could prove that there had been an escapement of income, and hence the reassessment notice and consequential orders were quashed and set aside. (AY. 2019-20)