1983 (11) TMI 156

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..... al by the revenue read as under: "1. The CIT (A) erred on facts and in law in holding that the ITO had not correctly invoked the provisions of sec. 147 of the IT Act, 1961. 2. In the absence of any reasons for holding that there was no justification for reopening the assessment u/s 147 (a) the finding of the CIT (A) is also bad in law. 3. The CIT (A) erred on facts and in law in holding that M/ .....

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..... fter going through the assessment records he could not locate any reasons recorded either in the order-sheet or in a separate sheet lying on the correspondence portion of the file. The ld. counsel for the assessee also pointed out that the ITO was requested to furnish a copy of the reasons recorded, but the same was not furnished to the assessee. In fact, there was no response from the ITO to such .....

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