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Assessee has raised the ground that the Honourable Commissioner of income tax (appeals) has erred in law as much as on the facts of thecaseby upholding the addition of Rs. 802600/– alleged to be bogus purchases without appreciating the fact that the learned assessing officer did not assume the jurisdiction to complete the assessment proceedings as the notice under section 143 (2) of The Income Tax Act, 1961 have been issued by him on the same day when the return of income has been filed by the appellant in compliance to notice under section 148 of the act, which clearly shows nonapplication of mind by him to the return of income filed by the appellant before the issuance of notice under section 143 (2) of the act and thus the reassessment is liable to be quashed.

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Sec. 147 of Income Tax Act, 1961— Reassessment —SURANA ENTERPRISES vs. ITO.[2020] 25 ITCD Online 090 (ITAT-DELHI)