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2022 (10) TMI 1030 - AT - Income TaxReopening of assessment u/s 147 - validity of notice - Reasons are handwritten and there is no signature of the AO thereon - HELD THAT:- As on verification of the assessment record including the order sheets from the date of recording of reasons clearly reveals that the order sheets by the AO from recording of reasons, issuing of notice u/s 148 and notices u/s 142(1) are handwritten and there is no signature of the AO thereon. Thus, safely hold that the AO neither complied with the statutory requirements and issuing notice u/s 148 of the Act nor complied with the law laid down by the Hon’ble Supreme Court in the case of reassessment proceedings. Consequently, as compelled to hold that the AO did not have valid jurisdiction to initiate reassessment proceedings and to issue notice u/s 148 of the Act to the assessee. Therefore, notice issued u/s 148 of the Act, reassessment proceedings and the impugned reassessment order are bad in law. Accordingly, the same are quashed and the consequent reassessment order made u/s 147 r.w. section 143(3) of the Act is annulled and the appeal of the assessee is allowed.
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