Reassessment Under Sec 147 Invalid: Lack of Independent Judgment and Nexus in Sec 148 Notice.

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....Reassessment u/s 147 - the suggestion of DDIT(Inv.) does not confer power to assume jurisdiction upon the AO to initiate reassessment proceedings - notice u/s 148 was issued without any application of mind and examination of the so called material and information received from the investigation wing to establish any nexus, even prima facie, with such information, by way of borrowed satisfaction - not sustainable....