Assessment Reopening u/s 147 Invalidated Due to Procedural Flaws in Notices Issued u/s 148A(b.

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....Reopening of assessment u/s 147 - the notices dated 21.03.2022 and 30.03.2022 though purported to have been issued under Clause (b) of Section 148A, on a reading of the annexure, it is clearly seen that the annexure does not contain information but it is a questionnaire. If that is so, then it goes without saying that what was intended by the assessing officer is to conduct an enquiry after receiving information from the assessee and the notice is deemed to be a notice under Section 148A (a) of the Act. - there is gross procedural error from the very inception of the proceedings rendering the same as bad in law. - HC....