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HC quashed reassessment proceedings initiated under s.147 due to procedural deficiencies and lack of specific information. AO failed to provide essential details including bank name in s.148A(b) notice, making it impossible for assessee to respond effectively. Despite assessee's objections and proof of closed ICICI account, AO proceeded hastily without proper verification. Department's failure to deny bank's confirmation of account closure and inability to establish prima facie connection between disputed account and assessee demonstrated non-compliance with s.148A procedural requirements. Court found reassessment notice invalid due to vague information, rushed decision-making, and department's failure to substantiate claims even during proceedings.
HC quashed reassessment proceedings initiated under s.147 due to procedural deficiencies and lack of specific information. AO failed to provide essential details including bank name in s.148A(b) notice, making it impossible for assessee to respond effectively. Despite assessee's objections and proof of closed ICICI account, AO proceeded hastily without proper verification. Department's failure to deny bank's confirmation of account closure and inability to establish prima facie connection between disputed account and assessee demonstrated non-compliance with s.148A procedural requirements. Court found reassessment notice invalid due to vague information, rushed decision-making, and department's failure to substantiate claims even during proceedings.
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