https://www.taxtmi.com/caselaws?id=446965 MP HC ruled on reassessment proceedings validity under amended Section 148A of IT Act. Petitioner claimed reply to show-cause notice was submitted but Revenue denied receiving it. Court found AO failed to consider petitioner's reply before passing order under Section 148A(d), violating procedural requirements. Rather than quashing proceedings entirely, HC adopted middle path directing AO to consider petitioner's reply first. If reply satisfactory, AO must drop Section 148A proceedings and recall order. If unsatisfactory, AO may proceed under Section 148. Court emphasized reasonable opportunity principle underlying Section 148A amendments. en-us Mon, 27 Mar 2023 00:00:00 +0530 Fri, 15 Dec 2023 10:54:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446965 MP HC ruled on reassessment proceedings validity under amended Section 148A of IT Act. Petitioner claimed reply to show-cause notice was submitted but Revenue denied receiving it. Court found AO failed to consider petitioner's reply before passing order under Section 148A(d), violating procedural requirements. Rather than quashing proceedings entirely, HC adopted middle path directing AO to consider petitioner's reply first. If reply satisfactory, AO must drop Section 148A proceedings and recall order. If unsatisfactory, AO may proceed under Section 148. Court emphasized reasonable opportunity principle underlying Section 148A amendments. Case-Laws Income Tax Mon, 27 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446965