Assessing Officer issued a show cause notice under section 148A(b) to the assessee for reopening the assessment on the ground that the assessee had made bogus purchases from a fictitious entity, ZMEPL. In response, the assessee clarified that it had not incurred any transactions with ZMEPL but with a contractor named ZIEPL. Pursuant thereto, Assessing Officer conducted a physical verification at address of said contractor and found that no such entity existed. The Assessing Officer held that the contractor was a non-existent bogus entity and passed an order under section 148A(d) and issued a notice under section 148. On writ, the Court held that since the conclusion regarding said contractor being a non-existent bogus entity was never put to assessee in show cause notice issued under section 148A(b), it was a violation of principles of natural justice. Since incriminating material was not put to assessee after closure of the original assessment proceedings, assessee was deprived of an opportunity to explain existence or otherwise of contractor. Accordingly the order under section 148A(d) and notice under section 148 were set aside. (AY. 2018-19)