https://www.taxtmi.com/caselaws?id=784323 The dominant issue was whether reassessment initiation under the Income-tax Act was vitiated because the order under s.148A(3) failed to disclose reasons for rejecting the assessee's response and for forming "reasons to believe" that income had escaped assessment, beyond a bare reference to a search under s.132 in the insurance sector. The HC held that the s.148A(3) order was non-speaking and did not address the assessee's specific objections, including the plea that the notice material was incomplete; absence of articulated reasoning rendered the decision to issue s.148 notices unsustainable. Consequently, the impugned s.148A(3) order and the consequential s.148 notices were set aside and the matter was remanded to the AO to pass fresh, reasoned orders based on the assessee's replies. en-us Fri, 19 Dec 2025 00:00:00 +0530 Fri, 02 Jan 2026 07:51:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784323 The dominant issue was whether reassessment initiation under the Income-tax Act was vitiated because the order under s.148A(3) failed to disclose reasons for rejecting the assessee's response and for forming "reasons to believe" that income had escaped assessment, beyond a bare reference to a search under s.132 in the insurance sector. The HC held that the s.148A(3) order was non-speaking and did not address the assessee's specific objections, including the plea that the notice material was incomplete; absence of articulated reasoning rendered the decision to issue s.148 notices unsustainable. Consequently, the impugned s.148A(3) order and the consequential s.148 notices were set aside and the matter was remanded to the AO to pass fresh, reasoned orders based on the assessee's replies. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784323