Assessment Reopening u/s 147 Challenged Due to Missing Details on Employee Status in Recorded Reasons.

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....Reopening of assessment u/s 147 - undisclosed activity of money lending and borrowing - the reasons for reopening of assessment has to be tested / examined only on the basis of the reasons recorded and those reasons cannot be improved upon and/or submissions much less substituted by an affidavit and/or oral submission. In the reasons for the reopening, the Assessing Officer does not state anywhere that specified person was an employee of petitioner. - HC....