Section 148 Notice issued for verification of information was not valid

Smt. Premwati Suman Vs ITO (ITAT Agra)

Conclusion: Notice under section 148 could not be issued for verification of information, but here the jurisdictional satisfaction of the essential requirement had to be shown that there had to be reason to believe that there was income chargeable to tax which was not there in the assessment order passed. Thus, the reasons recorded by AO were no reasons in the eye of law for assuming jurisdiction and the assessment orders u/s 144 read with 147 was quashed.

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