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2012 (7) TMI 689 - AT - Income TaxReassessment proceedings u/s 147 - Held that:- Notice u/s 148 in which no assessment year is mentioned cannot be treated as legal and valid notice. Further there is no material on record to show that the advocate of the dissolved firm had any authority to receive notice on behalf of the partners of the dissolved firm. The condition of service of a valid notice u/s 148 was not satisfied in this case - during reassessment proceedings the AO was satisfied with the explanation submitted by the assessee in respect of reasons recorded and did not make any addition on the basis of any of the recorded reasons but instead made additions on certain other points by making roving enquiries. As decided in RANBAXY LABORATORIES LIMITED Versus CIT [2011 (6) TMI 4 - DELHI HIGH COURT ]though AO had jurisdiction to reassess the income other than the income in respect of which proceedings u/s 147 were initiated, but he is not justified in doing so when the very reasons for initiation of those proceedings seized to survive - legislature could not be presumed to have intended to give blanket powers to the AO that on assuming jurisdiction u/s 147 regarding reassessment of escaped income he would keep on making roving enquiries and thereby including different items of income not connected or related with the reasons to believe on the basis of which he assumed jurisdiction - in favour of assessee.
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