Allowing the petition the Court held that  the reasons stated in the notice issued under section 148A(b) of the Income-tax Act, 1961 dated March 26, 2022 did not justify the conclusion that the assessee was not a professional. Unless the Department had the document to substantiate that the assessee was an employee in the respective hospitals, from whom he had received consideration and deductions were made wrongly under section 194J instead of section 192, the Department could not reopen the assessment. The assessee being an anesthesiologist was consulting in several hospitals and thus, had received remuneration for the services rendered to these hospitals, although on a monthly basis. There was no justification in reopening the assessment. The order under section 148A was not valid.(AY. 2018-19)