Notice u/s 148 cannot be issued for mere insufficient compliance to Letters

Shri. Pushpendra Singh Vs ITO (ITAT Agra)

Conclusion: Notice under section 148 issued on the basis of insufficient compliance to Letters dated 20.05.2011 and dated 02.02.2016 were wholly unauthorized in law as the reasons recorded must indicate that AO had applied his mind to the fact that income was chargeable to tax under the Act and it had exceeded maximum amount not chargeable to income Tax. Hence, reassessment was not valid as there were no reasons recorded by AO in the eye of law for assuming jurisdict

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