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2015 (8) TMI 1438 - HC - Income TaxValidity of re-opening of assessment u/s 147 - eligible reasons to believe - Held that:- As pointed out rightly by the ITAT in the impugned order, there was no application of mind by the AO when he issued notice under Section 148 - AO was also not aware that the Assessee had filed a return for the AY in question. No satisfaction was also been recorded by the ACIT. In the circumstances, the conclusion of the ITAT suffers from no legal infirmity. No substantial question of law arises.
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