https://www.taxtmi.com/caselaws?id=458234 Gujarat HC quashed reassessment proceedings initiated under Section 148. The court held that while a notice mentioning 30 days instead of 90 days was not fatal, the notice issued under Section 148A(b) was actually in nature of Section 148A(a) inquiry as it contained questionnaire seeking details rather than providing information about escaped income. The AO failed to consider assessee's detailed reply and did not form proper opinion based on available material. Since time limit for issuing proper Section 148A(b) notice had expired, the entire reassessment proceedings including the Section 148A(d) order and Section 148 notice were quashed due to procedural errors from inception. en-us Tue, 19 Dec 2023 00:00:00 +0530 Wed, 16 Oct 2024 20:43:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458234 Gujarat HC quashed reassessment proceedings initiated under Section 148. The court held that while a notice mentioning 30 days instead of 90 days was not fatal, the notice issued under Section 148A(b) was actually in nature of Section 148A(a) inquiry as it contained questionnaire seeking details rather than providing information about escaped income. The AO failed to consider assessee's detailed reply and did not form proper opinion based on available material. Since time limit for issuing proper Section 148A(b) notice had expired, the entire reassessment proceedings including the Section 148A(d) order and Section 148 notice were quashed due to procedural errors from inception. Case-Laws Income Tax Tue, 19 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458234