Notice U/s. 148 is invalid In absence of any live link with the reasons recorded and the belief formed

Prasad Koch Technik Tech Pvt Ltd Vs. Versus ACIT (Ahmedabad High Court)- The Assessing Officer supplied reasons he had recorded for reopening the assessment, which read as under:- “The assessee company filed its return of income on 22.12.2006, declaring total income of Rs. 1,00,86,370/-. The assessment u/s. 143(3) was finalised on 18.06.2008 determining the taxable income of Rs. 1,00,86,370/-. It is seen that the assessee company had made payment of Rs. 21,60,399/- in Foreign Company for purchase of raw materials. However, neither did the company deduct TDS on this amount nor any certificat...