Held, that the reply of the assessee was not given due consideration by the Assessing Officer. Hence, the order dated April 15, 2023 issued under section 148A(d) of the Income-tax Act, 1961, and the consequential notice dated April 16, 2023 issued under section 148 set aside (AY.2009-10)
Praveen Kumar Bhardwaj v. ACIT (2025) 482 ITR 855 (Delhi)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Order passed without considering reply of assessee-Not valid.[S. 147, 148, 148A(b) 148A(d), Art. 226]
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