Allowing the petition the Court held that the amount was already recorded and included in the return of income filed for the assessment year 2020-2021 and was duly processed by the Assessing Officer and it was offered for tax as part of business turnover. The notice under section 148 had been issued without application of mind and hence stood vitiated. The proceedings initiated under section 147 therefore, were not sustainable in law. The notice under section 148 dated March 31, 2024 had been issued by the Assistant Commissioner while the notices issued under section 133(6) were issued by the jurisdictional Assessing Officer. Court held that  the Assistant Commissioner was not competent to issue the notice. On both counts, the notices were not sustainable and hence were quashed.(AY. 2021-22)