Merely deriving information through faceless scheme u/s 135A...

Merely deriving information through faceless scheme u/s 135A cannot create arbitrary consequences. Safeguards are needed to prevent defective information leading to Section 148 notice. Not all information u/s 135A is sacrosanct or defect-free. Once defect is pointed out, AO must consider assessee's version before issuing Section 148 notice. AO failed to verify correctness of electronic information with assessee's explanation before issuing impugned Section 148 notice. AO needs to apply mind, verify materials, and form opinion before dispensing with Section 148A procedure for Section 148 notice based on Section 135A information. Impugned Section 148 notice quashed for non-application of mind and being arbitrary.