In HC proceedings the petition by the Petitioner challenging...

In HC proceedings the petition by the Petitioner challenging issuance of notice under s.148 was dismissed; the court held maintainability of writ under Articles 226/227 is distinct from the substantive adjudication under s.148A(d)/s.147 and is confined to whether credible information exists suggesting income has escaped assessment. The show-cause notice must be sufficiently reasoned to disclose the AO's intention and afford a reasonable opportunity to reply. The AO had recorded reasons based on material constituting credible information and applied mind; the Petitioner's merits-based defenses could not be tested at the notice stage. No interference was warranted at this intermediate stage; writ petition dismissed.