High Court Rules Notice Invalid: Assessing Officer Failed to Consider Taxpayer's Reply, Violating Income Tax Act Section 148A(c.

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....Reopening of assessment - validity of notice issued u/s 148A(b) - By not considering the reply of the Petitioner dated 29th March, 2022, the mandate of Section 148A(c) of the Act has been violated as it casts a duty on the Assessing Officer, by using the expression ‘shall’, to consider the reply of the Petitioner/Assessee in response to the notice under Section 148A(b) before making an order under Section 148A(d) of the Act. - HC....