Section 148A objections must be raised before the Assessing Officer, with further challenge preserved under law

The petitioner was required to place all objections, including those challenging the impugned notice, before the Assessing Officer in the proceedings under section 148A of the Income-tax Act, 1961. A supplementary reply was permitted within a week if the response period had expired, and the petitioner's right to challenge any adverse decision in accordance with law was preserved. The application was not decided on the substantive validity of the notice, as the Court directed the petitioner to pursue its objections in the statutory proceeding before the Assessing Officer.

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Issues: Whether the petitioner should be relegated to place all objections before the Assessing Officer in the proceedings under section 148A of the Income-tax Act, 1961 and whether the application required any further clarification on the merits of the impugned notice.

Analysis: The Court noted that the petitioner could raise all objections, including those relating to the challenge against the notice, in its reply before the Assessing Officer in the proceedings under section 148A of the Income-tax Act, 1961. It further permitted the filing of a supplementary reply within a week if the time to respond had expired. The Court also preserved the petitioner's right to challenge any adverse decision in accordance with law.

Conclusion: The application was not decided on the substantive validity of the notice and the petitioner was directed to pursue its objections before the Assessing Officer.

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