Facts: The petitioner, regularly files ITR, disclosing all sources of income. The ITO issued a notice under Section 148A, alleging that expenses incurred for the daughters marriage escaped assessment, based on information obtained during a search and seizure operation. The petitioner responded to the notice, providing details of his income sources and expenses related to the marriage, seeking a personal hearing, which was not granted, leading to the challenge of the notice and subsequent order under Section 148A in court.
Decision: The court held that the AO must ensure the petitioner is given an adequate and reasonable opportunity to contest the notice under Section 148, allowing the assessee to raise all issues during the hearing, as per previous SC pronouncements. The court emphasized the importance of providing the assessee with a fair chance to present their case and follow due procedure before issuing notices under Section 148. The court directed the revenue authority to adhere to proper procedures.

Facts: The petitioner, regularly files ITR, disclosing all sources of income. The ITO issued a notice under Section 148A, alleging that expenses incurred for the daughters marriage escaped assessment, based on information obtained during a search and seizure operation. The petitioner responded to the notice, providing details of his income sources and expenses related to the marriage, seeking a personal hearing, which was not granted, leading to the challenge of the notice and subsequent order under Section 148A in court.
Decision: The court held that the AO must ensure the petitioner is given an adequate and reasonable opportunity to contest the notice under Section 148, allowing the assessee to raise all issues during the hearing, as per previous SC pronouncements. The court emphasized the importance of providing the assessee with a fair chance to present their case and follow due procedure before issuing notices under Section 148. The court directed the revenue authority to adhere to proper procedures.

Facts: The petitioner, regularly files ITR, disclosing all sources of income. The ITO issued a notice under Section 148A, alleging that expenses incurred for the daughters marriage escaped assessment, based on information obtained during a search and seizure operation. The petitioner responded to the notice, providing details of his income sources and expenses related to the marriage, seeking a personal hearing, which was not granted, leading to the challenge of the notice and subsequent order under Section 148A in court.
Decision: The court held that the AO must ensure the petitioner is given an adequate and reasonable opportunity to contest the notice under Section 148, allowing the assessee to raise all issues during the hearing, as per previous SC pronouncements. The court emphasized the importance of providing the assessee with a fair chance to present their case and follow due procedure before issuing notices under Section 148. The court directed the revenue authority to adhere to proper procedures.

Facts: The petitioner, regularly files ITR, disclosing all sources of income. The ITO issued a notice under Section 148A, alleging that expenses incurred for the daughters marriage escaped assessment, based on information obtained during a search and seizure operation. The petitioner responded to the notice, providing details of his income sources and expenses related to the marriage, seeking a personal hearing, which was not granted, leading to the challenge of the notice and subsequent order under Section 148A in court.
Decision: The court held that the AO must ensure the petitioner is given an adequate and reasonable opportunity to contest the notice under Section 148, allowing the assessee to raise all issues during the hearing, as per previous SC pronouncements. The court emphasized the importance of providing the assessee with a fair chance to present their case and follow due procedure before issuing notices under Section 148. The court directed the revenue authority to adhere to proper procedures.

Facts: The petitioner, regularly files ITR, disclosing all sources of income. The ITO issued a notice under Section 148A, alleging that expenses incurred for the daughters marriage escaped assessment, based on information obtained during a search and seizure operation. The petitioner responded to the notice, providing details of his income sources and expenses related to the marriage, seeking a personal hearing, which was not granted, leading to the challenge of the notice and subsequent order under Section 148A in court.
Decision: The court held that the AO must ensure the petitioner is given an adequate and reasonable opportunity to contest the notice under Section 148, allowing the assessee to raise all issues during the hearing, as per previous SC pronouncements. The court emphasized the importance of providing the assessee with a fair chance to present their case and follow due procedure before issuing notices under Section 148. The court directed the revenue authority to adhere to proper procedures.

Facts: The petitioner, regularly files ITR, disclosing all sources of income. The ITO issued a notice under Section 148A, alleging that expenses incurred for the daughters marriage escaped assessment, based on information obtained during a search and seizure operation. The petitioner responded to the notice, providing details of his income sources and expenses related to the marriage, seeking a personal hearing, which was not granted, leading to the challenge of the notice and subsequent order under Section 148A in court.
Decision: The court held that the AO must ensure the petitioner is given an adequate and reasonable opportunity to contest the notice under Section 148, allowing the assessee to raise all issues during the hearing, as per previous SC pronouncements. The court emphasized the importance of providing the assessee with a fair chance to present their case and follow due procedure before issuing notices under Section 148. The court directed the revenue authority to adhere to proper procedures.