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5. The Ld. Assessing officer has erred in law in issuing twice reasons to believe with a letter dated 22.04.2013 and letter dated 20.03.2014 by simply saying that some typographically mistakes have crept in therefore letter dated 22.04.2013 is withdrawn. Reasons to believe cannot be altered, changed or supplemented.
6. The Ld. Assessing officer has erred in law in disposed off the objections of the appellant on the very same day vide letter dated Tarun Verma Vs. ITO, (Assessment Year: 2007-08) 24.03.2014 without application of mind which is totally unjustified and unwarranted.

4|Page Tarun Verma Vs. ITO, (Assessment Year: 2007-08) 67,21,980/- was paid in cash. It was also specified in the letter that assessee had accepted the same.

5) Then, just before 8 days of passing of the assessment order, the Id. AO issued another "Reasons to Believe" vide letter dated 20.03.2014 citing the reason that while sending "Reasons to Believe" vide letter dated 22.04.2013, some typographically mistakes had been crept in. Therefore letter dated 22.04.2013 was withdrawn. (Refer pg. no-55 of PB)

1.3 Your Honour, the Id. AO while issuing the another reasons to believe vide letter dated 20.03.2014 had taken the excuse that some typographically mistakes crept in in the letter of original reasons to believe dated 22.04.2013. (Refer page no- 55 of PB).

1.4 The typographical mistakes relates to misprinting/ typing error whereas in another reasons to believe issued vide letter dated 20.03.2014, Ld. AO made the addition as well as deletion of some facts mentioned in the reasons provided on 22.04.2013 which were the original reasons on the basis of which he had issued notice u/s 148 of Income Tax Act, 1961. 1.5 It is a trite law that for making the assessment u/s 147 of I.T Act, the reasons recorded should be clear and unambiguous and should not suffer from any vagueness.

10. Further suddenly on 20/03/2014 the Ld. assessing officer wrote a letter to the assessee stating that by sending the letter dated 22/04/2013 wherein the original reasons recorded were communicated, some typographical mistake have crept in. Therefore, the said letter dated 22/04/2013 is withdrawn. It was further stated that 22/03/2013 under section 147 of even date is enclosed. Suddenly the new reasons, which are placed at page No. 56 of the paper book, were supplied to the assessee. As per the new reasons the total payment of Rs. 7 858980/-, the sum paid by cheque of Rs. 11.37 Lacs, and the balance amount of Rs. 6721980/-paid in cash also remains unchanged. This was provided to the assessee when only 10 days time was left with the assessing officer for completion of the assessment. The assessee filed objection to this new reasons on 24/03/2014, which was disposed of on the same date without adverting to the any of the objection of the assessee. In the present case the figure stated by the Ld. assessing officer in reasons recorded as well as the actual fact of details of payment made by the assessee to the builder did not match. Assessee has already 15 | P a g e Tarun Verma Vs. ITO, (Assessment Year: 2007-08) paid a sum of Rs. 32 Lacs whereas the reasons mentioned by the assessing officer states that assessee has only paid Rs. 11.37 Lacs. Therefore, it is apparent that Ld. assessing officer has initiated reassessment proceedings without application of mind to the facts of the case to the information supplied by the investigation wing. The issue is squarely covered by the decision of the Hon'ble Delhi High Court in case of principle Commissioner of income tax versus G & G Pharma Ltd 384 ITR 147 (Delhi) wherein it has been held that:-