Bench: Shri Manomohan Das & Shri Rakesh Mishra
reassessment proceedings initiated by the department were bad in law as no notice u/s.148A and subsequent order passed u/s148(d) were served on your appellant. Further, copies of satisfaction note and sanction from higher authority was also not provided to your appellant before issuing notice u/s. 148. The notice u/s. 148 was issued by JAO and not by NFAC