Invocation of jurisdiction under Section 147 is not alternative to Section 263

Plaza Cable Industries Ltd Vs DCIT (ITAT Delhi) The maintainability of jurisdiction under Section 147 of the Act is central to the controversy in the instant case. On perusal of the reasons recorded under Section 148(2) of the Act qua the alleged escapement as reproduced in paragraph 6 above, it is straightaway noticed that the reasons have been recorded in a most perfunctory manner. The Assessing Officer has not even attempted to met the basic condition of holding “reason to believe” towards alleged escapement at all. The action of the Assessing Officer is highly tentative and non-descrip...