Bench: MR. JUSTICE AJAY TEWARI,MR. JUSTICE AVNEESH JHINGAN

disallowed. Thereafter notice under Section 148 of the Act was issued to the assessee claiming that the benefit of Section 80-I of the Act had wrongly been extended. Ultimately the Tribunal set aside this order holding that the primary condition of Section 147 of the Act viz 'reason to believe' (as defined by a plethora of judgments