Initiation of reassessment proceedings u/s. 147 based on incorrect facts is invalid

Shark Packaging (India) P. Ltd. Vs ITO (ITAT Delhi) ITAT Delhi held that initiation of reassessment proceedings u/s. 147 of the Income Tax Act by AO based on incorrect facts and without any verification, examination and evaluation of report of Investigation Wing and other material is invalid and unsustainable in law. Facts- Vide the present appeal, the appellant has mainly contested initiation of reassessment proceedings under section 147 of the Income Tax Act by issuance of notice under section 148 of the Income Tax Act. Appellant also contested that the reasons recorded by the Assessing Offi...