Section 148 Proceedings Challenged: Errors in Recorded Reasons Found Unrelated to Case Facts, Reopening u/s 147 Invalid.

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....Validity of proceedings u/s 148 - huge amount of discrepancy and mistakes in the ‘reasons recorded’, divorced from the facts of the case, cannot clothe the AO with the jurisdiction to reopen the assessment u/s 147 - no reasons to belief based on borrowed satisfaction....