Posted on by Vinamar Gupta

ITAT Amritsar in Karanvir Verma ITA 352/ASR/2014 pronounced on 18-05-2016, has held that issue of notice u/s 148 by the AO merely on the basis of the information from the Investigation Wing, and without independent application of mind by the AO to the material before him is not tenable in the eyes of law.

In this case, Investigation Wing had started  inquiry  against the assesse on the basis of unsigned photocopy of bayana.

Delhi High Court in SFIL Stock Broking Ltd 325 ITR 285 relied upon which promulgated  that notice u/s 148 can not be issued on the basis of borrowed satisfaction .