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TMI Blog2025 (1) TMI 391X X X X Extracts X X X X X X X X Extracts X X X X ..... rit in the contention that the allegations made in the impugned order u/s 148A (d) of the Act is at variance with that as was set out in the impugned notice issued u/s 148A (b) of the Act. The very purpose of issuing a notice is to enable the assessee to explain the information available with the AO and to establish that the said information does not indicate that the petitioner s income has escap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ms. Shreya Jain and Mr Gaurav Tanwar, Advocates. For the Respondent Through: Mr Siddhartha Singh, SSC. VIBHU BAKHRU, ACJ. (ORAL) 1. Issue notice. The learned counsel for the Revenue accepts notice. 2. The petitioner has filed the present petition, inter alia, impugning a notice dated 05.08.2024 (hereafter the impugned notice) issued under Section 148A (b) of the Income Tax Act, 1961 (hereafter the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 6AS and Aggregated GST Transactions report are bogus and the amounts paid by the assessee i.e. M/s Jindal Saw Ltd. (PAN:AABCS7280C) of Rs.79,17,086/-, which is in the form of expenditure, during the year under consideration be disallowed in its books of accounts accordingly. Therefore, amount paid by the assessee of Rs.79,17,086/-, which is in the form of expenditure, has remained unexplained and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ustainable as it is at variance with the allegations that were made in the impugned notice issued under Section 148A (b) of the Act. 8. The learned counsel appearing for the Revenue is unable to counter the aforesaid submission. 9. We find merit in the contention that the allegations made in the impugned order under Section 148A (d) of the Act is at variance with that as was set out in the impugne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s disclosed in its books of account and was also subject matter of the assessment. 13. In view of the above, we consider it apposite to set aside the impugned notice as well as the impugned order. It is so directed. 14. We, however, clarify that this order will not preclude the AO from issuing any fresh notice under Section 148A (b) of the Act, if the AO is of the view that the information is sugg ..... X X X X Extracts X X X X X X X X Extracts X X X X
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