Section 115A, 147 & 148 of the Income Tax Act, 1961 — Reassessment — A system generated notice detecting the assessee as a non filer does not automatically means that assessee has to be issued a notice under section 147 and even assuming that at time notice was issued the AO was perhaps not fully aware of a the relevant facts, once the assessee submits its objections, it is obligatory for the AO to apply his mind to those points. The Principal objection of the assessee that its investment in the shares of its subsidiary could not be treated as income was well founded, therefore, the fundamental premise that the investment by the assessee in the shares of its subsidiary amounted to income which had escaped assessment was flaw d and the question of such transaction forming live link for reasons to believe that income had escaped assessment was entirely without basis, thus the notice issued was invalid— Nestle SA vs. Assistant Commissioner of income tax [2019] 417 ITR 213 (Delhi)