In the result, the three appeals of the assessee are allowed for
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
section 282 of the Income Tax Act, 1961. 2. The Ld. CIT(A) erred on facts and law in confirming the validity of the proceedings initiated by the AO u/s 147/148 because no proper satisfaction as prescribed u/s 151 was recorded by the Pr. CIT that the case of the assessee was fit for issue of notice u/s