Asset definition: bank deposits and cash withdrawals qualify for reassessment, andAssessingOfficer notices upheld when prima facie satisfaction recorded.

Jurisdictional issuing of reassessment notices is upheld: the assessing officer's Section 148A(d) record of prima facie satisfaction and provision of opportunity to produce documents satisfied legal requirements, negating a prohibited roving inquiry, and thus the jurisdictional AO may validly issue the notice. Bank cash withdrawals and deposits constitute an "asset" for purposes of initiating reassessment under Section 149(1)(b) where reported transaction thresholds are met, so financial transaction information showing substantial cash movements can trigger reassessment proceedings. Precedential treatment favouring the Revenue governs the dispute and the challenge to the Section 148A(d) order was dismissed.

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Issues: Whether the jurisdictional Assessing Officer could validly issue the notice under Section 148 read with Section 148A(d) of the Income-tax Act, 1961 (as opposed to issuance only by a faceless assessing unit), and whether cash withdrawals/deposits qualify as an "asset" under Section 149(1)(b) of the Income-tax Act, 1961.

Analysis: The Court examined the Section 148A(d) order and the SFT information showing cash withdrawals of Rs. 1,87,95,000/-, noting that the amount exceeds the Rs. 50,00,000 threshold in Section 149(1)(b). The Explanation to Section 149(1)(b) expressly refers to deposits in bank accounts, supporting the view that such bank transactions fall within the definition of "asset" for the purposes of initiating reassessment proceedings. The Court further reviewed the Section 148A(d) record of prima facie opinion formed by the Assessing Officer and found that the AO had recorded requisite satisfaction and afforded the petitioner an opportunity to produce documents, negating the contention of a prohibited roving inquiry. The Court also considered precedent on the competence of jurisdictional AO versus faceless units and observed that the specific issue had been concluded in favour of the Revenue in TKS Builders v. Income Tax Officer (Delhi High Court), which governs the present dispute.

Conclusion: The issuance of the impugned notice by the jurisdictional Assessing Officer is valid; bank deposits/withdrawals fall within the definition of "asset" under Section 149(1)(b); the challenge to the Section 148A(d) order is dismissed. In favour of Revenue.

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