Reassessment not sustainable when reasons for initiation of proceedings Seized to Survive

Raj Bala Vs ITO (ITAT Delhi)

In the instant case, the AO had initiated proceedings u/s 147 for escapement of income of Rs.9,43,897/- which was the returned income filed prior to issue of notice u/s 148 in the belated return and as well as in the return filed in response to notice u/s 148 and since the AO has accepted the said returned income and proceeded to make various other additions without issuing fresh notice u/s 147/148, therefore, we are of the considered opinion that the AO has exceeded his jurisdiction in reassessi

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