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HC invalidated reassessment proceedings against the petitioner under Section 148A, finding a critical procedural defect. The AO's notice failed to substantiate the claim of a permanent establishment (PE) in India as originally proposed. The court determined that the grounds for issuing the reassessment notice did not align with the initial information provided, rendering the entire proceeding legally unsustainable. Consequently, the court set aside the notice under Sections 148, 148A(b), and 148A(d), effectively ruling in favor of the assessee and nullifying the tax department's reassessment attempt.
HC invalidated reassessment proceedings against the petitioner under Section 148A, finding a critical procedural defect. The AO's notice failed to substantiate the claim of a permanent establishment (PE) in India as originally proposed. The court determined that the grounds for issuing the reassessment notice did not align with the initial information provided, rendering the entire proceeding legally unsustainable. Consequently, the court set aside the notice under Sections 148, 148A(b), and 148A(d), effectively ruling in favor of the assessee and nullifying the tax department's reassessment attempt.
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