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Issues: Whether the impugned order under section 148A(d) of the Income-tax Act, 1961 and the notice under section 148 of the Income-tax Act, 1961 were liable to be set aside.
Analysis: The challenge to the reassessment notices was confined to the prayers relating to the impugned order and notice under the reassessment provisions. In view of the concession that the petitioner would restrict the petition to that relief, the Court proceeded to dispose of the matter on that basis.
Conclusion: The impugned order and notice were set aside and the petition was allowed.
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