In the result, the appeal for Asstt
Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta
220 (1976) 103 ITR 437 (SC) relied on". Therefore, the very assumption of jurisdiction u/s 147 on the basis of the "reason" recorded is vitiated. Thus, the reasons recorded are incorrect and vague and not based on any tangible material and merely based on borrowed satisfaction from investigation wing, it does not have live nexus with the formation of belief