The assessee company filed the return of income, subsequently revised, which was selected for scrutiny under CASS and the assessment was completed u/s 143(3).  Later on, the notice u/s 148 issued after the period of four years from the end of the relevant assessment year-the objections raised by the AO-demonstrates the opinion of the AO that the petitioner’s claim for set off of business loss and unabsorbed depreciation had correctly been allowed as per the provisions of the law.  However, in less than 45 days, the same AO, relying on the same audit objection, invoked the jurisdiction u/s 148 of the Act. Allowing the petition, the Court held that the notice issued by the AO on the ground of directions issued by the audit party and not in his personal satisfaction is not permissible in law. Larsen & Toubro Ltd. vs. State of Jharkhand (2017) 79 taxmann.com 267 (SC)/ (2017) 13 SCC 780; CIT (LTU) vs. Reliance Industries Ltd. (2017) 80 taxmann.com 242 / (2016) 382 ITR 574 (Bom.) and IL and FS Investment Managers Ltd. vs. ITO (2008) 298 ITR 32 (Bom.) followed. (AY. 2015-16)