Section 148A requires the Assessing Officer to follow the...

Section 148A requires the Assessing Officer to follow the prescribed sequence before issuing a reassessment notice under section 148. Where approval has been obtained to conduct an inquiry under section 148A(a), the Officer must conduct that inquiry before providing the taxpayer an opportunity to respond under section 148A(b). The text states that bypassing the approved inquiry renders the section 148A(b) notice invalid. Consequently, the subsequent order under section 148A(d) and notice under section 148 are also unsustainable. The reassessment proceedings were quashed, with the matter remitted for the required inquiry and further action in accordance with law.

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