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2022 (10) TMI 298 - HC - Income TaxReopening of assessment u/s 147 - as alleged notice issued u/s 148A(b) is that the petitioner has not filed ITR for the assessment year 2018-19 - HELD THAT:- As it is the petitioner’s case that all the high value transactions have been reported by the petitioner in its return of income and is willing to place on record the sale/purchase deed before the Assessing Officer, this Court sets aside the impugned order passed u/s 148A(d) of the Act as well as the notice issued under Section 148 and remands the matter back to the AO for a fresh decision in accordance with law. It shall be open to the AO to issue a supplementary notice explaining in detail the transactions, which were allegedly not reported by the petitioner within two weeks. The petitioner is also directed to file the sale/purchase deed as well as a supplementary reply, if required, with the AO within four weeks. AO is directed to pass a fresh order under Section 148A(d) of the Act within four weeks thereafter in accordance with law.
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