2008 (10) TMI 565

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....-02 and is directed against the order dated 15-2-2008 passed by the Income-tax Appellate Tribunal in ITA 4828/Delhi/2004. The only issue that is sought to be raised in this appeal pertains to the question of notice under section 147/148 of the Income-tax Act, 1961 (hereinafter referred to as the 'said Act'). 2. The assessment had been re-opened and an assessment order had been framed. Being aggri....

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.... was bad in law and the same was liable to be quashed. 3. We have heard the learned counsel for the appellant as well as the counsel for the respondent, who is present on advance notice. We find that the factual position is that no notice whatsoever was served on the assessee prior to the re-opening of the assessment proceedings. Proceedings under section 147 of the said Act cannot be initiated w....