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Issues: Whether the reassessment proceedings initiated by notice under Section 148 of the Income-tax Act, 1961 could be stayed pending reply, in view of the alleged non-compliance with Section 148A of the Act.
Analysis: The petition assailed the notice on the ground that the mandatory procedure introduced with effect from 1 April 2021, including inquiry and an opportunity of being heard under Section 148A, had not been followed. The Revenue sought time to file its reply.
Outcome: Ad-interim stay was granted on the proceedings arising from the notice under Section 148 for the assessment year 2013-2014, and the matter was directed to be listed for further hearing.