ITAT held that reassessment notice u/s 147/148 was invalid due...

ITAT held that reassessment notice u/s 147/148 was invalid due to lack of jurisdictional requirements. The AO failed to establish income escapement, as all primary facts were previously available during original assessment u/s 153A. The tribunal found no deliberate non-disclosure by the assessee, determining the reopening was merely a change of opinion. The notice was time-barred and issued beyond four years without substantive evidence of material fact concealment. Consequently, the tribunal allowed the assessee's appeal, quashing the reassessment proceedings as procedurally unsustainable and without legal foundation.