https://www.taxtmi.com/caselaws?id=793644 Reassessment under the pre-notice procedure was held jurisdictionally invalid where the section 148 notice was issued on an incorrect PAN and the assessee's section 148A(b) reply, including disclosure of the correct PAN, was not meaningfully considered. The statutory requirements of prior inquiry, consideration of reply, and reasoned satisfaction before notice under section 148 were treated as mandatory, so the defect went to jurisdiction. On merits, additions for cash deposits and FDRs were deleted because the assessee explained the source as business receipts and renewal of earlier deposits, the Revenue did not rebut that explanation, and double taxation of the same funds as separate unexplained items was impermissible. en-us Mon, 11 May 2026 00:00:00 +0530 Sat, 20 Jun 2026 08:04:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793644 Reassessment under the pre-notice procedure was held jurisdictionally invalid where the section 148 notice was issued on an incorrect PAN and the assessee's section 148A(b) reply, including disclosure of the correct PAN, was not meaningfully considered. The statutory requirements of prior inquiry, consideration of reply, and reasoned satisfaction before notice under section 148 were treated as mandatory, so the defect went to jurisdiction. On merits, additions for cash deposits and FDRs were deleted because the assessee explained the source as business receipts and renewal of earlier deposits, the Revenue did not rebut that explanation, and double taxation of the same funds as separate unexplained items was impermissible. Case-Laws Income Tax Mon, 11 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793644