Where the assessee has received a notice under Section 148A(b) with certain information then the Assessing officer cannot travel beyond the show cause notice and pass an order under Section 148A(d) on other grounds. Followed Commissioner of Customs v. Toyo Engineering India Ltd ( SC) ( WP ( T ) No. 254 of 2022 dt .1-12 -2022 )
U.S Associates v. PCIT (2023) 330 CTR 317(Chattisgarh)( HC)
S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Assessing Officer cannot travel beyond show cause notice- CBDT Circular dated 11.5. 2022 applicable if amount of income which has escaped tax is less than Rs. 50 lakhs- Order was quashed .[ S. 148A(b), 148(A)(d), Art , 226 ]