Reassessment u/s 148 Invalidated: Lack of Inquiry and Specific Facts by A.O and CIT(A) Highlights Mechanical Action.

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....Reassessment u/s 148 - neither the A.O nor the CIT(A) has made any enquiry from the Institution regarding certificate for tuition fees for the entire course - reasons being silent as to the specific facts, the vague allegation shows that action has been taken mechanically on the basis of alleged report of investigation wing, and, not on independent application of mind - Reassessment is non east of law....