Section 147&148 of the Income Tax Act, 1961– Reassessment– It cannot be said that the AO had reasons to believe that the income of the assessee had escaped assessment as AO has mentioned the basis of information as information received from Deputy Commissioner of income tax without any reference to the survey action carried out at the premises of the assessee and further correspondence made by his predecessor and AO has conveniently overlooked or to say skipped the facts and events in the reasons recorded so as to ward off the necessity to deal with the reply and explanations furnished by the assessee to his predecessor AO as well as with the result on the investigation carried out by Deputy director of Income tax and to point out as to why he was not satisfied with the explanation of the assessee– Blue Coast Infrastructure Development P. Ltd. vs. Deputy Commissioner of income tax [2020] 203 TTJ (Chandigarh) 327