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Notice issued under section 148 is vitiated on accounts of reasons stated supra and is hereby set-aside for want of valid jurisdiction and requisite approval.

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Sec. 147 of Income Tax Act, 1961— Reassessment — The material in possession of the AO has to be further linked by any reason to come to conclusion that the assessee has indulged in any activity which could give rise to reason to believe that income chargeable to tax has escaped assessment, in other words, unless the AO carries out the further examination after receipt of initial information from the Investigation wing, how can he conclude that income has escaped assessment and it is a fact that the assessee has filed her return of income and AO should have examined her return of income and carried out initial investigation before coming to the conclusion that income has escaped assessment, therefore, in the entirety of facts and circumstances of the case, the notice issued under section 148 cannot be sustained and the same is held to be bad in law - SHRI SHAILESH KUMAR CHATURVEDI V/s ITO - [2020] 27 ITCD Online 024 (ITAT-JAIPUR)

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