Proceedings u/s. 147 / 148 do not set aside original proceedings

RELEVANT PARAGRAPH 8.3 It cannot be disputed and it is not the case of either side that the reasons extracted herein above did not precede the issuance of notice under Section 148(1) of the Act. The requirement for recordal of reasons by the Assessing Officer before issuing a notice is provided for under sub-section (2) of Section 148 of the Act. 8.4 A perusal of the reasons would thus show that the Assessing Officer was of the view that the assessee’s income chargeable to tax had escaped assessment in the relevant assessment year by virtue of the fact that the assessee had charged to it...