Held that nowhere in the reasons recorded the assessee’s name specifically mentioned. The Assessing Officer could not and should not straightaway issue notice under section 148 of the Act and assume jurisdiction to reopen the assessment on receipt of the information that a company run by A had transactions with assessee. Reassessment was quashed. (AY.2014-15)
Dy. CIT v. Coal Sale Co. Ltd. (2022) 93 ITR 1 (SN) (Kol.)(Trib.)
S. 147 : Reassessment-Accommodation entries-Information from Investigation wing-Name of assessee was not appearing in statement-Reopening is bad in law. [S. 148]