Order u/s 148A(d) treated as notice u/s 148A(b) because reasons in order differed from those in original notice

Satluj Credit & Holdings Private Limited Vs ITO (Madras High Court)

Order u/s 148A(d) treated as notice u/s 148A(b) because reasons in the order differed from those in original notice

The Hon’ble High Court of Madras held in the above-mentioned case that if the reasons set out in a notice u/s 148A(b) to which the noticee is required to respond are different from the reasons contained in the order u/s 148A(d), the issuance of the notice would fail to serve its purpose and would be reduced to an empty formality.

In this case, the notice u/s 148A(b) proposed to tax

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