In the context of the question whether the AO CAN RELY ON REPORT OF INVESTIGATION WING the Jaipur bench of ITAT in 2019] 14 ITR (Trib)-OL 570 (ITAT[Jai]) held that the
Assessing Officer can rely on the report of the Director of Income-tax, Investigation Wing but where he is assuming jurisdiction under section 147, he is required to carry out further examination and analysis in order to establish the nexus between the material and formation of the belief that income has escaped assessment and in the absence thereof, the assumption of jurisdiction under section 147 had no legal basis.
In all propriety therefore it is legally desirable that the reasons must accompany a statement from the AO that he has carried out pre-examination and analysis beforehand in the absence thereof the reasons must be held as not his solely.
In the second course, the faceless scheme of assessment is silent as regards such pre-verification /examination and inquiry prior to the issue of notice u/s 148 as the assessment unit would send a request for verification only upon selection and assignment of the case. One thus needs to plus this loophole too.