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AO issued notice u/s 148A(b) making certain allegations. However, in subsequent order u/s 148A(d), AO raised grounds at variance with initial allegations in 148A(b) notice. HC held this deprived assessee of effective opportunity to explain information didn't indicate escaped income. AO didn't consider assessee's claim that alleged escaped income was disclosed and assessed. HC set aside 148A(b) notice and 148A(d) order.
AO issued notice u/s 148A(b) making certain allegations. However, in subsequent order u/s 148A(d), AO raised grounds at variance with initial allegations in 148A(b) notice. HC held this deprived assessee of effective opportunity to explain information didn't indicate escaped income. AO didn't consider assessee's claim that alleged escaped income was disclosed and assessed. HC set aside 148A(b) notice and 148A(d) order.
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