Reassessment Quashed: AO Lacked Independent 'Reasons to Believe' u/s 147, Violating Income Tax Act Mandate.

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....Reassessment u/s 147 - The full and true disclosure of the assessee is not in doubt - The ‘recording of reasons’ is mechanical and robotic and the mandate u/s 147 has not been complied with - It was incumbent upon the AO to have had independent ‘reasons to believe’ that there is escapement of tax, even if the initial nudge did emanate from the audit department - reassessment quashed....