https://www.taxtmi.com/caselaws?id=420006 Reassessment reopening failed because the recorded reason was factually wrong: the Assessing Officer proceeded on the basis that the assessee had purchased immovable property, whereas the record showed a sale by the assessee and co-sharers. In reassessment matters, the validity of reopening must be tested strictly on the reasons recorded, and those reasons cannot be substituted, improved, or supplemented later by affidavit or oral explanation. The reassessment notice, section 142(1) notice, and the order rejecting objections were quashed. The revenue was, however, left free to begin fresh proceedings on any other lawful basis supported by correctly recorded reasons. en-us Tue, 22 Mar 2022 00:00:00 +0530 Fri, 11 Aug 2023 11:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420006 Reassessment reopening failed because the recorded reason was factually wrong: the Assessing Officer proceeded on the basis that the assessee had purchased immovable property, whereas the record showed a sale by the assessee and co-sharers. In reassessment matters, the validity of reopening must be tested strictly on the reasons recorded, and those reasons cannot be substituted, improved, or supplemented later by affidavit or oral explanation. The reassessment notice, section 142(1) notice, and the order rejecting objections were quashed. The revenue was, however, left free to begin fresh proceedings on any other lawful basis supported by correctly recorded reasons. Case-Laws Income Tax Tue, 22 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420006