Held, that there was nothing on record to demonstrate that the Assessing Officer was in receipt of any information or had any material in his possession prior to his recording of reasons and issuance of notice under section 148, that income had escaped assessment. Thus, the additions made by the Assessing Officer was directed to be deleted. (AY. 2009-10).
Dhoot Stono Crafts P. Ltd. v. ACIT (2022)98 ITR 249 (Jaipur) (Trib)
S. 148: Reassessment-Notice-Reason to be formed before Issue of notice-Reassessment not valid. [S. 50C, 147]