“Order U/s 148A(d) cannot travel beyond show cause notice” is a good law even under the new reassessment scheme which is effective from 01.04.2021.
Delhi High Court held that the show cause notice issued under Section 148(A)(a) and the order passed under Section 148A(d) of the Income-tax Act, 1961 are based on distinct and separate grounds, which is not permitted. The show cause notice states that “it is seen that the Petitioner has made purchases from certain non-filers”. However no details or any information of these entities was provided to the Petitioner. It is not understood as to how the Petitioner would know which of the entities it dealt with were filers or non-filers! Accordingly, Section 148A(d) order is quashed. The rule that “Order cannot travel beyond show cause notice” which was prevalent under erstwhile reassessment scheme stands good in new reassessment scheme under Income-tax Act, 1961 which is effective from 01.04.2021.
The copy of the order wherein above position was discussed is as under:
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