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it would be improper to hold that the respondent Income Tax Officer had erred in invoking the reassessment jurisdiction vested with him under Section 147/148 of the Act, in the facts and circumstances case. Only when there are no grounds at all for invoking the reassessment jurisdiction under Section 148 of the Act, the notices can be challenged. Further, the appellant has himself replied and participated in the impugned proceedings. The reasons were also communicated to the appellant to which the appellant has also replied. Therefore, it is not open for the appellant to question the same to scuttle the proceedings initiated under the Act.

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Section 37(1) & 148 of the Income-tax Act, 1961—Business expenditure— Under Section 148, if the assessing officer has reasons to believe that income has escaped assessment he can issue a notice for passing order under Section 147 and the sufficiency of those reasons cannot be gone into by this Court and if relevant germane reasons exist and have been communicated to the assessee that is enough for reassessment proceedings to hold the field and in this case, during scrutiny the assessee was further asked to furnish the details of the invoices for the expenses incurred but the assessee failed to furnish the same, therefore, it would be improper to hold that Income Tax Officer had erred in invoking the reassessment jurisdiction vested with him under Section 147/148 of the Act, in the facts and circumstances case as the reasons were also communicated to the assessee to which the assessee has also replied - MOHAN RAVI V/s ITO - [2020] 268 TAXMAN 408 (MAD)

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