Reassessment proceedings under non-existent Section is Invalid

Maheshwari Roller Flour Mills Pvt. Ltd. Vs ITO (ITAT Delhi) Learned Counsel submitted that initiation under section 147 of the I.T. Act have been done by mentioning the wrong Section 147(b) of the I.T. Act which is deleted from the Income Tax Act w.e.f. 01.04.1989, therefore, reopening is done under non-existent Section in a mechanical manner without application of mind. It is well settled Law that validity of re-assessment proceedings is to be determined on the basis of the reasons recorded for reopening of the assessment. The A.O. in the Form for recording the reasons for initiating the re-a...