HC set aside notice u/s 148 and remanded matter to assessing...

HC set aside notice u/s 148 and remanded matter to assessing officer for fresh decision. Court held that procedural safeguards u/s 148A require meaningful opportunity of hearing, not mere formality. Assessing officer violated principles of natural justice by rejecting petitioner's response without providing adequate reasons or substantiating why audited accounts were unacceptable despite credible information from high risk transactions module indicating escaped assessment. Court emphasized that when rejecting assessee's contentions, appropriate reasons must be provided explaining why response is unacceptable. Notice and impugned order cannot be sustained without compliance with mandatory procedural requirements ensuring effective hearing opportunity.