D.C. AGRAWAL – [2022] 135 taxmann.com 323 (Article)
The Finance Act 2021 introduced a new reassessment scheme to assess/reassess income which has escaped assessment and for assessment in search and seizure, requisition, and survey cases. Under new law AO is not required to record reasons before issue of notice u/s 148. On the other hand, in certain cases the AO is required to issue notice u/s 148A on the basis of information received from two sources namely RMS (Risk Management Strategy) of CBDT and final objection by C&AG.
The AO may carryout inquiries as provided u/s 148A(a) after receipt of such information, call for comments of the assessee u/s 148A(b) on such information and inquiries, and pass an order u/s 148A(d) to the effect that it is a fit case to issue notice u/s 148 and thereafter getting approval from the prescribed authority issue notice u/s 148.
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