Order passed u/s 147 not borne out of any record is non-est

Saarthak Vanijya India Pvt Ltd Vs DCIT (ITAT Delhi) ITAT Delhi held that order passed by AO u/s 147 of the Income Tax Act not borne out of any record is non-est in the eyes of law. Facts- The assessee is engaged in the business of manufacturing of other paper articles. Return of income for AY 2013-14 was filed by assesses on 16.09.2013. Assessment u/s 153A was completed on 31.03.2016. The case of the assessee was re-opened u/s 148 of the I.T. Act, 1961. Accordingly, notice u/s 148 of the I.T. Act, 1961 dated 17.03.2021 was issued and served on the assessee. The Assessing Officer disallowed the...