Court invalidates tax notices, orders fresh assessment ensuring disclosure, response opportunity, and reasoned decision.

The court set aside the order issued under Section 148A(d) of the Income Tax Act, 1961, and invalidated the related notices. The Assessing Officer was directed to conduct a fresh assessment, ensuring proper information disclosure, opportunity for response and hearing, and issuance of a reasoned order. The misalignment between the notice and Case Related Information Details was a key issue. The writ petition was disposed of with these directions, instructing parties to comply with the digitally signed order.

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Issues involved:
The judgment concerns a writ petition related to Assessment Year (AY) 2017-18, challenging various notices and orders issued under the Income Tax Act, 1961.

Details of the Judgment:

Assailed Notices and Orders:
The petitioner challenged a notice u/s 148A(b) of the Act, an order passed u/s 148A(d) of the Act, and a consequential notice issued under Section 148 of the Act.

Misalignment Issue:
The main issue highlighted in the case was the misalignment between the allegation in the notice issued u/s 148A(b) and the Case Related Information Details (CRID).

Petitioner's Defenses:
The petitioner's defenses included discrepancies in the name and value of information in the notices, lack of provided reports/statements, and dealing with unlisted company shares which the petitioner denied.

Court's Observation:
The court observed that the CRID furnished to the petitioner did not align with the information in the notice, as it referred to a different individual, Mr. Rahul Dureja, instead of the petitioner.

Court's Decision:
The court decided to set aside the order issued u/s 148A(d) of the Act and consequently invalidated the notice issued u/s 148A(b) and other show cause notices. The Assessing Officer (AO) was directed to conduct a fresh assessment, providing material information to the petitioner, allowing a response, a personal hearing, and issuing a speaking order.

Conclusion:
The writ petition was disposed of with the above directions, and parties were instructed to act based on the digitally signed copy of the order.

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