Question And Answer
Subject: Validity of notice u/s 148
Category: 
Querist: Suresh Goyal
Answered by:
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Date: June 26, 2023
Query asked by Suresh Goyal

Dear Sir,

After Supreme Court judgment of Union of India vs. Ashish Aggarwal 439 ITR 1, assessee received notice u/s 148A(b), assessee filed reply and received order u/s 148A(d) alongwith notice u/s 148 for A.Y. 2013-14 on 22.07.2022. In the notice received u/s 148, four reasons were mentioned but none of them is ticked. As the notice does not specify the cause / reason in the notice, whether notice is valid or not. Copy of the notice is attached.

Please clarify.

Thanking You,

Yours Sincerely,

CA S.K. Goyal
A.R.

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I don’t think that should be a reason to hold the Notice under section 148 of the Act as invalid as the assessee has already been issued a show cause notice under section 148A(b) of the Act, the assessee’s objections are recorded and a reasoned order is passed under section 148A(d) of the Act.



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