Notice u/s 148 based on vague notice u/s. 154 not maintainable -SC

SUPREME COURT OF INDIA Additional Commissioner of Income-tax v/s. Shreyas Gramin Bank CIVIL APPEAL NO. 4801 OF 2007 SEPTEMBER 12, 2012 ORDER Heard learned counsel on both sides. We have gone through the Notice under Section 154 of the Income Tax Act, 1961 [‘Act’, for short]. We find that the said notice is totally vague. The Assessing Officer has not even indicated as to on what basis he has allowed excess set-off. Notice under Section 154 of the Act, therefore, was not maintainable. The second notice under Section 148 of the Act was issued squarely on the basis of...