ITAT quashes section 147/148 proceeding as reasons to believe not existed anymore

Bansiwala Iron & Steel Rolling Mills Vs DCIT (ITAT Jaipur)

Since the A.O. is a quasi-judicial authority, who has to collect the evidences, material and then to adjudicate the matter after due and complete application of mind. The A.O. expected to record his own satisfaction before reaching to any conclusion. In our view, the A.O. cannot borrow his satisfaction by merely relying upon material or the result of the other reports of other investigation agency unless he himself has examined the issue in hand by due and full a

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