Passing of Section 148A(d) order based on fresh ground untenable: Delhi HC

Tosca Master Vs DCIT (Delhi High Court) Delhi High Court held that passing of order by the revenue under section 148A(d) of the Income Tax Act on the basis of fresh ground which was never taken up with the assessee in the notice is untenable in law. Facts- Respondent vide notice dated 22.03.2023 u/s. 148A(b) of the Act, sought to initiate assessment u/s. 147 read with Section 148 of the Act, pursuant to the information flagged by the Risk Management Strategy, alleging that in the absence of return of income, the source of income of the investment remained unexplained. Petitioner contested that...