Recording of reasons after due application of mind is sine qua non for valid section 148 notice

Omkam developers Ltd. Vs ITO (ITAT Delhi) 1. The reasons recorded are based on suspicion, which is evident from the words used in reasons recorded, i.e., “it appears that assessee M/s Omkam Developers Ltd. has received bogus share capital/share premium to the tune of ₹ 1.93 Crores. 2. The Assessing Officer has just accepted the information in a mechanical manner and failed to record an independent satisfaction 3. Recording of reasons after due application of mind is sine qua non for valid notice u/s 148 of the Act 4. In the relevant column No.13 in the form for recording reasons for satisf...