On writ, the Court held that at the stage of passing an order under section 148A, cross-examination of a person whose statement has been relied upon is not required, and such cross-examination would become necessary only at the stage when an order under section 147 is to be passed, and the statement is relied upon by the Assessing Officer. Where reassessment proceedings were initiated on the basis of a statement of a third party recorded under section 132(4), mere denial/non-completion of cross-examination of said third party did not vitiate the order under section 148A(d). However, the opportunity of cross-examination shall be provided to the petitioner before passing of final assessment order.