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Reassessment under ss.147/148 was held void ab initio as the AO recorded "reasons" merely on Investigation Wing information indicating a possibility of similar transactions, without any seized material, independent enquiry, or application of mind, amounting to borrowed satisfaction and lack of jurisdiction. Given the year was unabated and no incriminating material was forwarded, the AO ought not to have assumed jurisdiction under s.147, and the failure to follow the due statutory route (including s.153C where applicable) vitiated initiation itself. Since confirmations had already been furnished during s.142(1) proceedings, rejection/forensic testing at appellate stage could not cure the foundational defect. Appeal allowed on jurisdiction, without examining merits. - ITAT
Reassessment under ss.147/148 was held void ab initio as the AO recorded "reasons" merely on Investigation Wing information indicating a possibility of similar transactions, without any seized material, independent enquiry, or application of mind, amounting to borrowed satisfaction and lack of jurisdiction. Given the year was unabated and no incriminating material was forwarded, the AO ought not to have assumed jurisdiction under s.147, and the failure to follow the due statutory route (including s.153C where applicable) vitiated initiation itself. Since confirmations had already been furnished during s.142(1) proceedings, rejection/forensic testing at appellate stage could not cure the foundational defect. Appeal allowed on jurisdiction, without examining merits. - ITAT
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