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Reassessment proceedings under section 148A require the Assessing Officer to examine the taxpayer's explanation and supporting documents before deciding that a reassessment notice should issue. Where alleged undisclosed amounts are disputed as not constituting business turnover, the officer must determine their character and record cogent reasons. Non-consideration of the response and material invalidates the section 148A(3) order and consequential notice, requiring reconsideration; approval based on the quashed order does not survive.
Reassessment proceedings under section 148A require the Assessing Officer to examine the taxpayer's explanation and supporting documents before deciding that a reassessment notice should issue. Where alleged undisclosed amounts are disputed as not constituting business turnover, the officer must determine their character and record cogent reasons. Non-consideration of the response and material invalidates the section 148A(3) order and consequential notice, requiring reconsideration; approval based on the quashed order does not survive.
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