LATE. SH. GURMAIL. SINGH. S/O. SH. LAL SINGH,SRI MUKATSAR vs. DY.COMMISSIONER OF INCOME TAX CIRCLE -II, BATHINDA
Appeals are disposed of in the terms and observation made as above
ITA 58/ASR/2019[2013-14]Status: DisposedITAT Amritsar25 May 2023AY 2013-14
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. S. R. Kaushik, CIT-DR
Section 147Section 148Section 151(2)Section 250(6)Section 282Section 69A
282 of the Income-tax Act, 1961. The proceedings u/s 147/148 are void ab-initio because the reasons to believe recorded by the AO are infact reasons to suspect.
That no satisfaction was recorded by the Principle CIT which was mandatory under the provisions of Section 151(1) & reliance for the contention has been placed on the following judgments