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Section 147 & 148 of the Income Tax Act, 1961— Reassessment— Assessment was reopened solely on the basis of information received from Principal Directorate of income Tax (Investigation) and the AO had been carried away by the report of the Investigation Wing without making any independent verification to justify the reopening and the reasons for reopening of the assessment were devoid of any independent application of mind by the AO, thus, the notice issued under section 148 deserved to be quashed — Magan Behari Lal vs. Deputy Commissioner of income tax [2019] 75 ITR (trib) 322 (Delhi)