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HC held that erroneous attachment of another taxpayer's information to section 148 notice due to inadvertence does not invalidate reassessment proceedings. However, the subsequent order dated 03.02.2025 was deemed unsustainable as it overlooked this apparent error, indicating lack of proper consideration of petitioner's objections. Court directed revenue authorities to rectify notice by providing correct Insight Portal information and Specified Authority approval within one week, allowing petitioner to file fresh objections. The procedural error was treated as rectifiable rather than fatal, balancing administrative efficiency with taxpayer rights under reassessment provisions.
HC held that erroneous attachment of another taxpayer's information to section 148 notice due to inadvertence does not invalidate reassessment proceedings. However, the subsequent order dated 03.02.2025 was deemed unsustainable as it overlooked this apparent error, indicating lack of proper consideration of petitioner's objections. Court directed revenue authorities to rectify notice by providing correct Insight Portal information and Specified Authority approval within one week, allowing petitioner to file fresh objections. The procedural error was treated as rectifiable rather than fatal, balancing administrative efficiency with taxpayer rights under reassessment provisions.
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