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71 results for “reassessment u/s 147”+ Section 153(2)clear

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Key Topics

Section 153C131Section 14868Section 143(2)46Addition to Income41Section 13232Section 148A30Section 14728Condonation of Delay27Section 143(3)

DEPUTY COMMISSIONER OF INCOME TAX (IT), VISAKHAPATNAM vs. SHRI APPARAO MUKKAMALA, USA

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

ITA 354/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

Section 144C(3)Section 147Section 148Section 153CSection 69A

153. 28. The language of explanation 2 to new Section 148 is akin to Section 153A and Section 153C. Corollary being that after seizing of operational period of Section 153A to 153D, the cases being dealt thereunder were circumscribed in the scope of newly substituted Section 148. 29. The Department has not set up a case that for initiating proceedings

Showing 1–20 of 71 · Page 1 of 4

22
Section 14420
Search & Seizure19
Deduction15

SAMANTHAPUDI LAVANYA,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, , VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 704/VIZ/2019[2009-10]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2009-10

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI SIVA RAMA RAJU,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 709/VIZ/2019[2011-12]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2011-12

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KUNUMURI KRISHNA KUMARI,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 711/VIZ/2019[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI LAKSHMI SIRISHA ,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF I NCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 724/VIZ/2019[2010-011]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-011

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI LAKSHMI UMA KATYAINI ,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 717/VIZ/2019[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI BHASKARA RAJU,,BAPULAPADU MANDAL vs. THE THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 74/VIZ/2020[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI LAKSHMI SIRISHA ,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 723/VIZ/2019[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI SIVA RAMA RAJU,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 707/VIZ/2019[2009-10]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2009-10

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

SAMANTHAPUDI RAJA RAMESH ,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 720/VIZ/2019[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI LAKSHMI UMA KATYAINI ,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 718/VIZ/2019[2011-12]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2011-12

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

SAMANTHAPUDI RAJA RAMESH,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 719/VIZ/2019[2009-10]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2009-10

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI LAKSHMI UMA KATYAINI ,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 716/VIZ/2019[2009-10]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2009-10

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

SAMANTHAPUDI LAVANYA,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 705/VIZ/2019[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI SIVA RAMA RAJU,VIJAYAWADA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 708/VIZ/2019[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KUNUMURI KRISHNA KUMARI,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 710/VIZ/2019[2009-10]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2009-10

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KUNUMURI KRISHNA KUMARI,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 712/VIZ/2019[2011-12]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2011-12

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI PRASAD,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 713/VIZ/2019[2009-10]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2009-10

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI PRASAD,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 715/VIZ/2019[2011-12]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2011-12

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded

KANUMURI PRASAD,BAPULAPADU MANDAL vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE,, VIJAYAWADA

In the result, appeals of the assessees are allowed

ITA 714/VIZ/2019[2010-11]Status: DisposedITAT Visakhapatnam27 Apr 2021AY 2010-11

Bench: Shri N.K.Choudhry, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bleआयकरअपीऱसं./I.T.A.No.704/Viz/2019 To 706/Viz/2019 (निर्धारणवर्ा/Assessment Year:2009-10 To 2011-12) Smt.Samanthapudi Lavanya Vs. Asst.Commissioner Of D.No.5-1033-1, Vijayawada Road Income Tax Hanuman Junction, Central Circle Bapulapadu Mandal Vijayawada Krishna Dist. [Pan : Cnbps7658N]

2. The learned Commissioner of Income Tax (Appeals) ought to have quashed - the notice issued by the assessing officer u/s 148 as invalid and consequently ought to have quashed the reassessment proceedings as void ab initio. 3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) ought to have quashed the reopening as the reasons recorded