TMI Blog2022 (9) TMI 1573X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee in the notice issued u/s 148A(b) so that the Assessee can provide a meaningful response at the stage of inquiry u/s 148A proceedings. Consequently, as the show cause notice issued u/s 148A(b) of the Act as well as the subsequent notice are bereft of any details, this Court is of the view that the Revenue by asking the Petitioner-Assessee to respond to the aforesaid vague show cause notice was virtually asking the Petitioner to search for a needle in a haystack . As Revenue now states that the Respondent shall supply all the relevant material documents and information in its possession, the impugned order passed u/s 149A(d) as well as the notice issued u/s 148 are set aside with a direction to Revenue to issue a supplementary notice in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had taken entries of Rs.2,73,02,153/- from twenty-eight bogus entities maintained by Sh.Deepak Nanjyani. He states that names of none of the twenty-eight bogus entities from whom the Petitioner had allegedly purchased raw material were mentioned in the show cause notice. 4. He emphasises that in the relevant Assessment Year, the Petitioner had a turnover of about Rs.638 crores and had purchased raw material worth about Rs.390 crores. Consequently, learned senior counsel for the Petitioner contends that there has been violation of principles of natural justice as the Petitioner has been denied an effective opportunity to rebut the information available with the Asseesing Offcer. 5. Mr.Abhishek Maratha, learned Senior Standing Counsel for th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urt in Sabh Infrastructure Ltd. vs. Asst. CIT, MANU/DE/2989/2017 : 398 ITR 198 (Del). 7. Consequently, as the show cause notice issued under Section 148A(b) of the Act as well as the subsequent notice dated 18th May, 2022 are bereft of any details, this Court is of the view that the Revenue by asking the Petitioner-Assessee to respond to the aforesaid vague show cause notice was virtually asking the Petitioner to search for a needle in a haystack . 8. However, as learned counsel for the Respondent-Revenue now states that the Respondent shall supply all the relevant material documents and information in its possession, the impugned order passed under Section 149A(d) of the Act as well as the notice issued under Section 148 of the Act dated 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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