There was a dissonance between input received from insight portal and what was noted in section 148A(b) notice with regard to amount which had escaped assessment. The assessee being informed by petitioner that there was discrepancy between what was stated in section 148A(b) notice and input received from said insight portal. Assessing Officer proceeded on same course and passed an order under section 148A(d) of the Act. On writ the Court held that there was c non-application of mind hence the order and notices were set aside. (AY. 2016-17)
Rahul Aggarwal v. ITO (2023) 293 Taxman 57 (Delhi)(HC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Dissonance between input received from insight portal-Non application of mind-Order and notice were set aside. [S. 148, 148A(b), 148A(d), Art. 226]