Assessing Officer's jurisdiction to initiate section 147 proceedings invalid; section 148 notice quashed for improper assumption.

Protective assessment - Validity of the jurisdiction assumed by the A.O for initiating proceedings u/s. 147 - it is beyond comprehension that the AO after holding a belief that the amount was the income of another person, could have thereafter simultaneously held the said amount as the income of the assessee chargeable to tax that had escaped assessment - notice issued by the A.O u/s. 148 quashed for want of valid assumption of jurisdiction. - AT .....

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