HIGH COURT OF JUDICATURE AT ALLAHABAD WRIT TAX No. - 762 of 2024 Court No. - 39 HON'BLE SAUMITRA DAYAL SINGH, J. HON'BLE SWARUPAMA CHATURVEDI, J. 1. Heard Mr. K.P. Singh Kaushik, Senior Advocate, assisted by Ms. Anjana Singh, learned counsel for the original petitioner/appellant and Mr. Ankur Agarwal, learned Senior Standing Counsel for the revenue. 2. The prayer made in the writ petition is confined to the challenge to the show cause notice dated 15.04.2024, issued under Section 148A of the Income Tax Act, 1961 (hereinafter referred to as the Act), for the A.Y. 2017-18. Also, challenge has been raised to the order dated 22.04.2024, passed under Section 154 of the Act, for A.Y. 2017-18. 3. Upon exchange of affidavits, it transpires, the revenue authorities have, of their own, reached satisfaction that the information giving rise to the impugned reassessment proceedings had been considered in the first reassessment proceedings initiated vide show cause notice dated 30.03.2021, which culminated in the order dated 02.03.2022. In that regard, by means of Supplementary Affidavit, it has been stated as below: "5. That as per the information uploaded on RMS, the bank in which unexplained credits were appearing was Punjab National Bank. However, in the case of the initial reassessment proceedings in which order u/s 147 r.w.s. 144B of the Income Tax Act, 1961 was passed on 02.03.2022, the reassessment proceedings had been initiated on the basis of information of cash deposit in account maintained with Oriental Bank of Commerce. 6. That in this case, the notice in the second instance appears to have been issued due to change in the name of bank from Oriental Bank of Commerce to Punjab National Bank in Versus Counsel for Petitioner(s) : Anjana Singh Counsel for Respondent(s) : Ankur Agarwal, Gaurav Mahajan Kanti Kaushik-Huf .....Petitioner(s) Income Tax Officer And 2 Others .....Respondent(s) the information received. On verification of the details of bank accounts and facts of the case, it is revealed that the entire credit transactions for the year under consideration had been examined by the Assessing Officer during the initial reassessment proceedings. Copy of the information received is filed herewith as ANNEXURE No. SCA1. 7. That from the above, it is apparent that the information flagged in accordance with the risk management strategy did not constitute fresh information necessitating the subsequent reopening of reassessment. Thus, the contention of the assessee in this regard seems to be acceptable." 4. In view of the above, the writ petition succeeds and is allowed to the extent of limited prayer made. Consequently, the reassessment proceedings for the A.Y. 2017-18 initiated by the show cause notice dated 15.04.2024, are quashed. September 17, 2026 Prakhar WTAX No. 762 of 2024 2 (Swarupama Chaturvedi,J.) (Saumitra Dayal Singh,J.) Digitally signed by :- PRAKHAR SRIVASTAVA High Court of Judicature at Allahabad