Missing foundational allegation in Section 148A(b) notice cannot be incorporated by issuing a supplementary notice

Catchy Prop-Build Private Limited Vs ACIT (Delhi High Court) Having perused the paper book and having heard learned counsel for the parties, this Court is of the view that in the notice issued under Section 148A(b) of the Act, the petitioner was never asked to explain the source of funds that were used by Manu Garments to purchase the shares of Bert Marketing Pvt. Ltd. This Court is further of the opinion that if the foundational allegation is missing in the notice issued under Section 148A(b) of the Act, the same cannot be incorporated by issuing a supplementary notice. In the case of Mahashi...