TaxTMI 
TaxTMI 
2018 (1) TMI 193
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.... for the appellant - revenue. He has pressed into service the following substantial questions of law : "(1) Whether on the facts and in the circumstances of the case and in law, ITAT was justified in annulling the assessment proceedings where the assessee has never objected during the course of assessment proceedings regarding the validity of notice u/s.148; and in light of the affidavit filed b....
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....h March, 2010 whereas he recorded reasons for reopening the assessment on 31st March, 2010. The CIT (A) held that recording of reasons was sine qua non for issuing a notice under Section 148 of the said Act. Therefore, the first Appellate Authority proceeded to set aside the reassessment made by the Assessing Officer. Being aggrieved by the order of the first Appellate Authority, the appellant - r....
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....2) of Section 148 of the said Act. He would, therefore, submit that the proceedings were not initiated on the basis of the notice dated 30th March, 2010. 4 We have given careful consideration to the submissions. An Appeal against the order of Assessing Officer was preferred by the respondent - assessee on 25th January, 2011. During the pendency of the said Appeal which was decided on 20th June, 2....