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The HC set aside the order and notice dated 30.06.2025 and remitted the matter to the AO for fresh consideration. The petitioner, having undertaken not to contend that the order under s.148A(3) is time-barred and not to challenge the legality of the notice under s.148A(1), relinquished those pleas. The AO is directed to examine the documents identified by the parties and any other material he considers necessary, to afford the petitioner prior notice with reasonable time to furnish further documents or replies, and thereafter to pass a reasoned, speaking order under the relevant provisions, applying s.149(1)(b) as appropriate.
The HC set aside the order and notice dated 30.06.2025 and remitted the matter to the AO for fresh consideration. The petitioner, having undertaken not to contend that the order under s.148A(3) is time-barred and not to challenge the legality of the notice under s.148A(1), relinquished those pleas. The AO is directed to examine the documents identified by the parties and any other material he considers necessary, to afford the petitioner prior notice with reasonable time to furnish further documents or replies, and thereafter to pass a reasoned, speaking order under the relevant provisions, applying s.149(1)(b) as appropriate.
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