Section 40(a)(ia) & 147 of the Income-tax Act, 1961—Reassessment —The record of the case clearly reveals that the Assessing Officer has not accepted the objections raised by the audit party and on the contrary has objected to such objections by communicating internally, therefore, the Assessing Officer has not formed any independent belief that the income chargeable to tax has escaped assessment and on the contrary has stated that he had considered the applicability of provisions of section 14A and was satisfied in adopting 0.5% of average value of investment for disallowance under section 14A, thus, the notice under section 148 has merely been issued on the basis of the audit objection without the Assessing Officer having formed the requisite belief regarding escapement of income as contemplated under section 147 - - PR. CIT V/s LALIT BAGAI - [2019] 267 TAXMAN 443 (DELHI)