Tribunal  held that, the proceedings initiated under S. 153A of the Act were still pending for adjudication before the Commissioner (Appeals) when the notice under S. 148 of the Act was issued. The same issue of addition of Rs. 12 lakhs, being loan received from KVF, was the subject matter of the section 153A proceedings as well as the section 148 proceedings. There could not be two parallel proceedings on a similar subject matter and proceedings initiated first must come to an end for making way for initiation of other proceedings on the same subject matter. According to the statutory scheme and the provisions of the Act during the pendency of proceedings under S. 153A the Assessing Officer was not empowered to issue notice under S. 147 / 148 . Therefore the reassessment proceedings for assessment year 2003-04 suffered from the basic defect of the reassessment notice being illegal and, therefore, the reassessment proceedings could not be sustained. Accordingly the reassessment proceedings for the assessment year 2003-04 were quashed as void ab initio. ( AY.2003-04, 2004-05)