Reopening invalid if Officer issuing notice different from officer recording reasons

Nishi Kapoor Vs ITO (ITAT Delhi)

The Assessing Officer who has valid jurisdiction over the case of the assessee shall record reasons u/s 148(2) for reassessment proceedings, otherwise issue of notice u/s 148 is not valid. 

Reopening notice invalid If the officer who had issued the notice under section 148 of the Act, was different from the officer who had recorded the reasons and Assessment deserved to be quashed on this ground alone.

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