IMPORTANT POINT
The central legal point established in the judgment is the requirement for accurate and substantiated information to trigger reassessment proceedings under the Income Tax Act, and the court's authority to set aside such proceedings in case of mistakes or discrepancies.

JUDGMENT

Rajiv Shakdher, J. (Oral) - We had heard learned counsel for the parties at some length on 16.12.2022, after which we had recorded the broad contours of the matter. For convenience, the relevant parts of the order dated 16.12.2022 are set forth hereafter:

"1. The matter is taken up today once again as the order dated 28.07.2022 passed by the respondent/revenue under Section 148A(d) of the Income Tax Act, 1961 [in short, "the Act"] was discrepant.

1.1 The discrepancy in the aforementioned order concerns the bank account number of one Mr Ramesh Kumar Bagri maintained with IDBI Bank.

2. Mr C.S. Aggarwal, learned senior counsel, who appears on behalf of the petitioner, says that he has got yet another certificate titled "To Whom It May Concern" dated 15.12.2022 with respect to the other account number i.e., 264102000006354 indicated in the aforementioned order.

2.1 A copy of this communication has been handed over to Mr Abhishek Maratha.

2.2 The Registry will scan and upload the same so that it remains part of the case file.

3. In any event, for the moment, we are not taking into account this document till it is verified by the respondent/revenue. However, that, by itself, will not come in the way of the petitioner being granted interim relief, for the reasons set out hereinafter.

4. This writ petition is directed against the order dated 28.07.2022 passed under Section 148A(d) of the Income Tax Act, 1961 [in short, "the Act"] and the consequent notice of even date i.e., 28.07.2022 issued under Section 148 of the Act, concerning Assessment Year (AY) 2016-17.

5. Mr Aggarwal says that reassessment proceedings have been commenced without any information and material being supplied to the petitioner.

6. The record shows that notice, in the first instance, was issued to the petitioner under Section 148 of the Act on 07.04.2021. Since the new regime kicked in, a fresh notice under Section 148A(b) dated 27.05.2022 was issued to the petitioner.

7. The record shows that the allegation against the petitioner is that it has received bogus entry from an entry provider i.e., one Mr Ramesh Kumar Bagri.

8. A perusal of the order dated 28.07.2022 would show that in the suspicious transaction referred to under the heading "information available and action initiated", concerning Mr Bagri, there is no reference to the petitioner.

9. Mr Abhishek Maratha, who appears on behalf of the respondent/revenue, has placed before us the information received by the assessing officer i.e., Mr Sanjeev Bimbisariye. The following information was furnished to us by way of a tabular chart:

10. As would be evident from the above extract, in the last entry in the table, dated 12.08.2015, under the head "particulars", there is a reference to an entity going by the name Tirupati Trading Corporation [which is also the name of the petitioner] and against the said entity it is shown that an amount equivalent to Rs.1,76,00,000/- has been credited. The suggestion being that the aforementioned amount has been received by Mr Bagri.

11. Mr Aggarwal, in rebuttal, qua this aspect of the matter, has referred us to two documents which are appended on pages 147-148 of the case file and are marked as Annexure P12.

11.1. These are copies of "whomsoever it may concern" certificates issued by the Central Bank of India [in short,