Shanti Prime Publication Pvt. Ltd.
Sec. 148 of Income-tax Act, 1961— Reassessment — Assessment has been reopened on a review of the information that was already on record which is not permissible in law — It is absolutely clear that there was no new material in front of the AO to form 'reason to believe' that any income has escaped assessment and the power of the learned CIT(A) is co-terminus with that of the AO and he has made statement on record that there was no new material before the AO so to resort to the provisions of s. 147/148 — Dy. CIT vs. Jamnalal Sons (P) Ltd. [2020] 203 TTJ 1008 (NAG)