Held that the recording of reasons was done mechanical manner without verifying the records. Reassessment was quashed. Followed Sagar Enterprises v. ACIT (2002) 257 ITR 335 (Guj.)(HC). (AY.2010-11)
Jaspal Singh v. ITO (SMC) (2021) 88 ITR 407 / 211 TTJ 25 (UO) (Chd.) (Trib.)
S. 148 : Reassessment-Notice-Recording of reason stating that the assessee failed to file return of income-Contradictory to facts on record-Order was quashed. [S. 143(3), 147]