In the recorded reasons the AO has mentioned that the assessee had borrowed cash loan and violated the provisions of section 269SS of the Act . On writ the Court held that the reasons recorded did not mention that income has escaped assessment , hence the notice issued was quashed . ( WP No. 3620 of 2019 dt .15 -1 -222 )( AY. 2012 -13)
Sanjeev Amritlal Chheda v. ITO (2022) The Chamber’s Journal – February -P. 176 ( Bom)( HC)
S. 147 : Reassessment – Borrowed cash loan – Violation of section 269SS – Reason did not mention that income that escaped assessment – Mechanical approval -Reassessment notice is invalid and quashed [ S. 148 , 151, 269SS, 269T , Art , 226 ]