Reassessment proceedings quashed as order passed u/s. 148A(d) was non-speaking: ITAT Delhi

Reshma Kamal Abichandani Vs ACIT (ITAT Delhi)

ITAT Delhi held that order passed u/s. 148A(d) is non-speaking since AO failed to provide adequate counter explanation against reasons furnished by the assessee. Accordingly, assessment u/s. 147 non-est and void ab initio.

Facts- The assessee is a non-resident in India since 1997 residing in Philippines and does not have any income in India and, for that reason, no ITR was filed in India. Notably, the assessee was issued a notice u/s 148A(d) of the Act on 31.03.2022 by the AO. The said notice was ssued since retu

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