Reassessment u/s. 147 not justified as reasons recorded is plagued with several defects: ITAT Delhi

Montreaux Resorts Pvt Ltd Vs ITO (ITAT Delhi) ITAT Delhi held that reasons recorded for exercising the jurisdiction is plagued with several defects of critical nature. Thus, due to lack of jurisdiction u/s. 147 of the Income Tax Act reassessment proceedings held as bad-in-law. Facts- Assessee has preferred the present appeal against order of the National Faceless Appeal Centre. The assessee has inter alia challenged the assumption of jurisdiction under Section 147 of the Act and alleged that the prerequisite of Section 147 and Section 151 of the Act has not been clearly fulfilled in the presen...