Skipper Infrabuilders (P.) Ltd. v. UOI 2024] 163 taxmann.com 10 (Cal) (HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Given only two working days to comply the notice-Notice and order is quashed and set aside. [S.148, 148A(b), 148A(d), Art. 226]

The assessee has requested for fifteen days time to comply the notice m however only two working days time was granted and  the order under section 148A(d) was passed and notice under section 148 of the Act is issued. On writ allowing the petition  the Court held that  assesseee is  denied reasonable opportunity to appropriately respond to show cause and thus, impugned order passed under section 148A(d) as well as consequential notice issued under section 148 were to be set aside. (AY 2018-19)