Red Chilli International Sales v. ITO (2022) 288 Taxman 107 (P& H)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Failure to consider the submission-Proceedings not concluded-Writ petition was dismissed. [S. 148, 148A(b), 148A(d), Art. 226, 227]

Assessee filed  writ petition challenged order passed under section 148A(d) along with notice issued under section 148 on ground that response filed by assessee to notice under section 148A(b) had not been considered. Dismissing the petition the Court held that   proceedings initiated were yet to be concluded by a Assessing authority exercise of jurisdiction under article 226/227 of Constitution at this intermediate stage was not warranted. (AY. 2018-19)