2026 (1) TMI 79

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....MESWAR RAO AND HON'BLE MR. JUSTICE VINOD KUMAR For the Petitioner Through: Mr Sachit Jolly, Sr Advocate with Mr Abhyudaya Shankar Bajpai, Mr Sohum Dua, Ms Manvi and Ms. Ghunaim Siddiqui, Advocates. For the Respondents Through: Mr Siddhartha Sinha, SSC and Ms Easha Gurung, JSC. V. KAMESWAR RAO, J. (ORAL) 1. These petitions [W.P.(C) 19288/2025 & W.P.(C) 19296/2025] have been filed by....

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....he Act in respect of relevant AYs. 3. Mr Sachit Jolly, learned Senior Counsel for the petitioner has drawn our attention to page no. 45 of W.P.(C) 19288/2025 and page no. 37 of W.P.(C) 19296/2025 which are notices issued under Section 148A(1) of the Act to contend that they are vague notices and does not specify the reasons to allege that the income of the petitioner has escaped assessment exce....

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....e chargeable to tax has escaped assessment in the relevant AY. 5. On the other hand, Mr Siddhartha Sinha, learned SSC appearing for the Revenue, would justify the notices which have been issued under Section 148A(1) of the Act; orders passed under Section 148A(3) of the Act; and notices issued under Section 148 of the Act, stating that, it is pursuant to the investigation that the proceedings h....

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....ct (in both the petitions) and remand the matters back to the AO for passing reasoned orders, afresh on the basis of the replies given by the petitioner to the notices under Section 148A(1) of the Act. 8. We also make it clear that the petitioner in its replies dated 28.03.2025 has also stated that the notices issued by the respondents are incomplete as same does not provide complete informatio....