Facts of the Case
The petitioner, Standard Chartered Bank UK, challenged:
- Notice
dated 31.03.2023 issued under Section 148A(b)
- Order
dated 03.05.2023 under Section 148A(d)
- Consequential
notice under Section 148
The reassessment was initiated on the basis of alleged receipt
of ₹156.15 crore as income/fees for technical services from Vodafone
Mobile Services Ltd.
The petitioner:
- Filed
a reply within time (26.04.2023)
- Raised
objections regarding lack of jurisdiction and non-supply of
material
However, the Assessing Officer passed the order without considering the reply.
Issues Involved
- Whether
reassessment proceedings are valid when:
- The
reply of the assessee is not considered
- Whether
reassessment is sustainable without:
- Furnishing
underlying material to the assessee
- Whether
notice issued by an officer lacking jurisdiction is valid
Petitioner’s Arguments
- The
notice was issued by an officer without jurisdiction, as the
original assessment was completed in Mumbai
- The material/information
relied upon was not provided, violating principles of natural justice
- The
reply submitted was not considered at all before passing the order
under Section 148A(d)
Respondent’s Arguments
- Revenue
relied on material indicating receipt of substantial income
- Argued
based on available records without filing counter affidavit
- Contended
that reassessment was validly initiated
Court’s Findings / Order
- The
Assessing Officer failed to consider the petitioner’s reply, which
is mandatory
- This
constitutes a violation of principles of natural justice
- Consequently:
- Order
under Section 148A(d) dated 03.05.2023 set aside
- Notice
under Section 148 quashed
However, the Court granted liberty to the Revenue:
- To
pass a fresh order
- Subject
to:
- Furnishing
material/information to the petitioner
- Granting
opportunity to file response
- Providing
personal hearing
- Passing
a reasoned (speaking) order
Important Clarifications by the Court
- Consideration
of reply under Section 148A(b) is mandatory, not procedural formality
- Non-supply
of material violates natural justice
- Reassessment
must be conducted with due application of mind
- Personal
hearing and speaking order are essential safeguards
Link to download the order -
https://delhihighcourt.nic.in/app/showFileJudgment/RAS21072023CW96062023_142301.pdf
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