TMI Blog2020 (3) TMI 884X X X X Extracts X X X X X X X X Extracts X X X X ..... e at the very least that the assessing officer sign the same. Without signatures, the document becomes anonymous piece of paper to which no credence can be given. The action under Section 147 of the Act is quasi-judicial action and if it is permitted that such action can be done as anonymously, it would have very serious consequences in other cases also. If the Court accepts such pieces of pape ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e are that the assessee had offered some income for tax. The assessment was complete under Section 143(1) of the Act but subsequently notice under section 148 was given. What weighed with the Tribunal was that reasons recorded under Section 147 of the Act to reach the belief that income and escaped assessment was unsigned and undated and consequently, the Tribunal set aside the proceedings on this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ustified in quashing the reassessment proceedings without appreciating the fact that the assessee himself admitted long term capital gain in the return of income filed in compliance to notice issued u/s 148? C. Whether on the facts and in the cicumstances of the case, the Hon'ble ITAT was justified in admitting the fresh evidence as well as accepting the copy of reasons obtained by the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nder Section 147 of the Act have been met out would be at the very least that the assessing officer sign the same. Without signatures, the document becomes anonymous piece of paper to which no credence can be given. The action under Section 147 of the Act is quasi-judicial action and if it is permitted that such action can be done as anonymously, it would have very serious consequences in other ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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