AO recorded reasons on same returned income- Reassessment Invalid

Raj Bala and Joginder Dahiya Vs ITO (ITAT Delhi)

AO recording reasons on same returned income considering escaped assessment but making various other additions of other than accepted returned income declared invalid and deleted in light of Explanation 3 and held issuance of fresh notice u/s 148 on other issues is mandatory.

Since, in the instant case, the AO had initiated proceedings u/s 147 for escapement of income of Rs.9,43,897/- which was the returned income filed prior to issue of notice u/s 148

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