Assessee is a partnership firm and filed its return of income for AY 2019-20 declaring total income of Rs. NIL. DIT(Inv.), Ghaziabad issued summons u/s. 131(1A) requiring petitioner to furnish details and purpose of loan advanced to two ladies of Rs. 1.75 Crores. Subsequently, Notice u/s. 148A(b) issued upon the assessee firm that income not commensurate with transaction of Rs. 1.75 Crores, to which the petitioner filed reply on 27.03.2023. AO passed Order u/s. 148A(d) rejecting the objections and issued Notice u/s. 148. High Court observed that detailed adjudication on the merits of information available with the AO at the stage of passing order under section 148A(d) of the Act. Merits of the information referable to Section 148A thus remains subject to the reassessment proceedings initiated vide notice u/s. 148 of the Act. The scope of decision under section 148A(d) is limited to the existence or otherwise of information which suggests that income chargeable to tax has escaped assessment. High Court relied on the decision of Hon’ble Supreme Court in the case of Anshul Jain vs. PCIT [2022] 499 ITR 256 (SC) whereby it was observed that if the petitioner had any grievance on merits, the same has to be agitated before the AO during the reassessment proceedings and interference of Court is not called for. Writ petition was dismissed accordingly.(AY. 2019-20)