Held that there is Live link between material and belief necessary for issue of notice. Notice based solely on information received from Investigation Wing which did not specify any material disclosing No independent examination conducted by Assessing Officer. Notice and order rejecting assessee’s objections set aside.(AY.2011-12) (AY. 2014-15)
CNB Finwiz Ltd. v. Dy. CIT (2025) 479 ITR 125 (Delhi)(HC) Sanjay Kaul v. ITO (2025) 479 ITR 146 (Delhi)(HC)
S.147: Reassessment-After the expiry of four years-Suspicion-Information received from Investigation Wing-No independent examination-Reassessment notice and order disposing the objection was quashed and set aside.[S. 148, Art. 226]
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