Hon’ble High Court held that if the notice issued under section 148 of the Income-tax Act, 1961 merely quotes the information flagged on the insight portal without neither depicting therein the results of the independent investigation conducted if any of the said information by the Assessing Officer nor connecting the assessee to the transactions specified in the said information then the reassessment proceedings initiated through issuance of the said notice is bad in law.
The decision was rendered under the erstwhile reassessment provisions.
In my view, the aforesaid ratio decidendi laid down by the court would apply to the notice issued under section 148A(b) under the new reassessment scheme.