Reassessment Notice u/s 148 Quashed: Investment in Subsidiary Shares Not Income Escaping Assessment.

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....Reassessment Notice u/s 148 - even assuming that at the time notice was issued the Respondent was not fully aware of all the relevant facts, once the Petitioner submitted its objections drawing his attention to the specific legal position, it was obligatory for the AO to have applied his mind to those points - the fundamental premise that the investment in the shares of its subsidiary amounted to ‘income’ which had escaped assessment was flawed - notice quashed....