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HC invalidated reassessment proceedings initiated under s148A(b) based on alleged bogus capital expenses identified through CRIU/VRU information. Revenue's physical verification and subsequent order under s148A(d) violated natural justice principles as assessee was not given opportunity to respond to allegations regarding non-existent entity. Court emphasized that post original assessment closure, AO becomes functus officio and jurisdiction for reassessment requires proper disclosure of incriminating material to assessee. Physical verification findings about entity's non-existence at Jasola address were not communicated via show cause notice, making the reassessment proceedings procedurally defective. Order set aside in assessee's favor.
HC invalidated reassessment proceedings initiated under s148A(b) based on alleged bogus capital expenses identified through CRIU/VRU information. Revenue's physical verification and subsequent order under s148A(d) violated natural justice principles as assessee was not given opportunity to respond to allegations regarding non-existent entity. Court emphasized that post original assessment closure, AO becomes functus officio and jurisdiction for reassessment requires proper disclosure of incriminating material to assessee. Physical verification findings about entity's non-existence at Jasola address were not communicated via show cause notice, making the reassessment proceedings procedurally defective. Order set aside in assessee's favor.
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