V. S. Dhandapani and Son v. ITO (2023)453 ITR 277/ 292 Taxman 364 / 222 DTR 337/ (2024) 337 CTR 367 (Mad)(HC)

S. 148A : Reassessment – Conducting inquiry, providing opportunity before issue of notice – Typographical errors -Will not invalidate notice -Writ petition was dismissed.[S. 147, 148,148A(d), 151 Art. 226]

Dismissing the petition, the Court held that  section 148A is a codified mechanism for the benefit of the assessee.  As regards the letter of the Additional Commissioner to the Principal Commissioner, it was an inter-office communication where the Additional Commissioner had opined that it was not a fit case to issue notice under section 148. The Principal Chief Commissioner who admittedly was the “specified authority” within the meaning of section 148A(d) read with section 151 had clearly opined that it was a fit case for issuing notice under section 148. The order under section 148A(d) and the subsequent notice under section 148 need not be interfered with.(AY. 2014-15)