Dismissing the petition the Court held that the order passed under section 148A(d) need not be interfered with. The assessee could raise all grounds available including that the order was time barred and was on a mere change of opinion before the Assessing Officer at the appropriate stage.
Shiv Mettalicks Pvt. Ltd. v. PCIT (2023) 453 ITR 544 (Orissa)(HC)
S. 148A : Reassessment – Conducting inquiry, providing opportunity before issue of notice – Alternative remedy -Writ petition was dismissed. [S. 147, 148, 148A(b), 148A(b), 148A(d), Art. 226]