Held that the reassessment proceedings in respect of the polytechnic were patently illegal, bad in law and without the fundamental requirement for acquiring the jurisdiction under section 147 / 148 that the income should have escaped the assessment. (AY. 2009-10)
Sardar Vallabhbhai Patel Education Society v. ITO (2022) 446 ITR 278 (Guj.)(HC)
S. 147 : Reassessment-No tangible material-Notice not valid. [S. 148, Art. 226]