Reassessment notice fairness requires a full opportunity to respond before expanded allegations and penalty proceedings are pursued.

Reassessment proceedings under Section 148A(b) were found to have expanded beyond the narrower factual basis on which the show-cause notice was issued, without giving commensurate opportunity to respond. Limited interference was therefore justified to permit the taxpayer to file a detailed reply and to require the Assessing Officer to reconsider the matter after due application of mind to that response. The assessment order and the consequent penalty show-cause notices were quashed in part, with liberty granted to submit the response within the time allowed.

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Issues: Whether the assessment order and the subsequent penalty show-cause notices arising from reassessment proceedings deserved to be quashed with liberty to file a detailed response.

Analysis: The assessment was made after the show-cause notice under Section 148A(b) had proceeded on a narrower factual basis, while the later proceedings expanded the alleged deficiency without according commensurate opportunity to meet that basis. In the circumstances, limited interference was considered justified to enable the petitioner to place a detailed response and to ensure that the Assessing Officer thereafter decides the matter on due consideration of that response.

Conclusion: The assessment order and the consequent penalty show-cause notices were quashed in part, with liberty to the petitioner to file a detailed response within the time granted and with directions for fresh consideration by the Assessing Officer.

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