Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
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:- i. Smt. Nirmal Kaur vs. Dy. CIT International Taxation, Chandigarh I.T.A No. 575/ASR/2016