Personal hearing requirement before reassessment order led to quashing and remand for fresh consideration.

An order under Section 148A(d) and the consequential notice under Section 148 were quashed because no personal hearing was granted before adverse action was taken. The Court treated the absence of hearing as material, left the merits open, and remanded the matter for fresh de novo consideration by the Faceless Assessing Officer after affording the petitioner a personal hearing and an opportunity to file written submissions.

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Issues: Whether the order issued under Section 148A(d) of the Income-tax Act, 1961, and the consequential notice under Section 148 of the Income-tax Act, 1961, were liable to be quashed for want of personal hearing and whether the matter required remand for fresh consideration.

Analysis: The order was passed without granting a personal hearing, and the respondents fairly accepted that the absence of such hearing was material. The Court therefore quashed the impugned order and the consequential notice, while leaving the merits open and directing fresh consideration by the Faceless Assessing Officer after affording the petitioner a personal hearing and an opportunity to file written submissions.

Conclusion: The impugned order and the consequential notice were set aside and the matter was remanded for de novo consideration after personal hearing to the petitioner.

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