Validity of reopening of assessment - Reasons were recorded by...

Validity of reopening of assessment - Reasons were recorded by the Assessing Officer in an arbitrary manner and there is no application of mind by the AO. For example, the reasons stated that assessee has deposited an amount in his bank account to the tune of X amount, whereas the actual amount deposited in the bank account by the assessee was to the tune of Y Amount hence reasons were recorded on arbitrary basis and there is no application of mind by the AO. - AT