2022 (6) TMI 155 - Income Tax

Reopening of assessment u/s 147 - Notice issued under section 148A(b) - As submitted Petitioner did not have the opportunity to file a reply and the order under Section 148A(d) was not on merits, the Respondent has no objection if the matter is remanded back to the Assessing Officer for a fresh decision - HELD THAT:- Keeping in view the impugned order under Section 148A(d) and the notice issued under Section 148 of the Act dated 31^st March, 2022 for the Assessment Year 2018-19 are set aside and the matter is remanded back to the Assessing Officer for a fresh decision. The Petitioner is given liberty to file its additional reply to the show cause notice issued under Section 148A(b) of the Act within two weeks. The Assessing Officer is directed to decide the matter by way of a reasoned order in accordance with law within eight weeks thereafter. This Court clarifies that it has not commented on the merits of the controversy.