2013 (8) TMI 77

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....the Respondent : Manish Bhatt and Mrs. Mauna M. Bhatt. ORDER:- PER : Akil Kureshi Heard learned counsel for the parties for final disposal of the petition. 2. The petitioner has challenged a notice dated 10-2-2012 as at Annexure-A to the petition issued by the respondent Assessing Officer under section 148 of the Income-tax Act, 1961 ("the Act" for short), seeking to reopen assessment ....

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.... 4. The petitioner thereupon raised objections to the notice for reopening under communication dated 1-2-2013. Such objections were disposed of by the Assessing Officer on 22-2-2013 rejecting the same. Hence the petition. 5. From the events recorded by the Assessing Officer, his objection for the petitioner's claim of bad debt of Rs. 9.42 lakhs (rounded off) appears to be that only sum of Rs. ....

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....on of computation of income it was noticed that...". Thus the material on the basis of which the reasons are recorded form part of the original record. Further neither any order rejecting the petitioner's objection nor before us the Revenue contends that the belief of the Assessing Officer that income chargeable to tax has escaped assessment, is based on any material outside of the record. Additio....