10. In the present case before us, the reasons recorded by the AO nowhere connect with the escapement of income or quantify the same or give any reasonable or rational nexus, reasons cannot be sustained. Accordingly, we are of the view that the issued notice u/s. 148 of the Act is invalid and bad in law, thus the same is quashed and consequently the reassessment is also quashed and accordingly, ground raised by the assessee in the cross objection are allowed and resultantly, the cross objection filed by the assessee stand allowed.

11. Since we have already quashed the notice u/s 148 of the Act and its consequent reassessment, as aforesaid in the assessee’s cross objection by allowing it, the grounds raised in the Revenue‘s appeal have become infructuous and thus rejected. Accordingly, the appeal filed by the Revenue stand dismissed.

12. In the result, the assessee’s cross objection stand allowed and revenue’s appeal is dismissed, in the aforesaid manner.