Reassessment based on Vague reasons without application of mind is invalid

Smt. Sapna Chauhan Vs ITO (ITAT Agra) It is settled position in law that the question of Jurisdiction is not a matter of acquiescence. The proprietary of Notice under section 148, based upon ‘reasons recorded’ is not dependent upon the objection or no objection by the assessee at the stage of assessment. If the Reasons recorded, independently can withstand the test of judicial scrutiny, only such reasons will confer jurisdiction to issue Notice and frame assessment in pursuance thereto. However, if the reasons recorded, upon being challenged at any stage of proceedings fails to withstand t...