Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)
u/s. 147 of the Act is invalid and assessment made on such invalid initiation deserves to be quashed and may kindly be quashed. I.T.A No. 148/Rjt/2021 & 09/Rjt/2022 A.Y. 2011-12 & 2017-18 Page No 5 Smt. Rani Hareram Sahani vs. ITO 5. The Ld. CIT(A)erred on facts as also in law in confirming addition