Assessing Officer issued a notice under section 148A on ground that assessee had allegedly invested in penny scrips of two companies and had received certain amount from a bogus company.  During e-proceedings, assessee submitted its response and requested for providing copies of adverse materials and statements found on basis of which notice under section 148A was issued. It further sought for an opportunity to cross examine person who might have given such adverse deposition and also requested for a copy of approval of specified authority before issuance of said notice. Despite consistently reiterating this request, revenue failed to give any response.  On writ single judge dismissed the petition . On appeal the Division Bench held that notice claimed to be issued under clause (b) of section 148A did not contain any information regarding reason for reopening but contained a questionnaire, thus, notice was deemed to be a notice under clause (a) of section 148A of the Act.  On facts there was a gross procedural error from very inception of proceedings and thus order passed under clause (d) of section 148A was bad in law and set aside. Matter was remanded back to Assessing Officer with direction to furnish full information as sought for by assessee and thereafter conduct an enquiry as provided for under clause (a) under section 148(A) and accordingly proceed in accordance with law. (AY. 2018-19)