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The respondent passed an order u/s 148A(d) and issued a consequential notice u/s 148 based on information gathered during a surprise check conducted by enforcement officials, relating to documents produced by the petitioner in support of their case when filing a reply. The petitioner claimed violation of Section 148A(b) and principles of natural justice, as the order/notice pertained to an issue not covered by the two show cause notices. However, the court held that the respondent acted based on irregularities found in the documents submitted by the petitioner during scrutiny of their replies. The petitioner was directed to file returns u/s 148, and if aggrieved, could file a reply to the notice. The court found no merit in the petitioner's contention.
The respondent passed an order u/s 148A(d) and issued a consequential notice u/s 148 based on information gathered during a surprise check conducted by enforcement officials, relating to documents produced by the petitioner in support of their case when filing a reply. The petitioner claimed violation of Section 148A(b) and principles of natural justice, as the order/notice pertained to an issue not covered by the two show cause notices. However, the court held that the respondent acted based on irregularities found in the documents submitted by the petitioner during scrutiny of their replies. The petitioner was directed to file returns u/s 148, and if aggrieved, could file a reply to the notice. The court found no merit in the petitioner's contention.
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