Delhi high court coming down heavily on income tax deptt for passing general /template orders u/s 148A(d) (copy of order marked to cbdt for necessary action)
and inter alia held

SIGNIFICANCE OF ISSUANCE OF A SHOW CAUSE NOTICE AT A STAGE PRIOR TO ISSUANCE OF A REASSESSMENT NOTICE UNDER SECTION 148 OF THE ACT HAS BEEN LOST ON THE RESPONDENTS.

“16. This Court is of the opinion that significance of issuance of a show cause notice at a stage prior to issuance of a reassessment notice under Section 148 of the Act has been lost on the Respondents.

This Court takes judicial notice that in a majority of reassessment cases post 1st April, 2021, the orders under Section 148A(d) of the Act use a template / general reason
to reject the defence of the assessee on merits, namely, “found devoid of any merit because the assessee company has failed to produce the relevant documents in respect of transactions mentioned in show cause notice……..it is established that the assessee has no proper explanation……”

Consequently, this Court is of the opinion that a progressive as well as futuristic scheme of re-assessment whose intent is laudatory has in its implementation not only been rendered nugatory but has also had an unintended opposite result.”