High Court Quashes Assessment Order: Revenue Failed to Record Reasons for Reopening Under Income Tax Act Section 147.

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....Reopening of assessment u/s 147 - reasons to believe - It is settled law that the reasons for reopening an assessment can be tested and examined only on the basis of the reasons recorded at the time of issuing the notice under Section 148 of the Act. The Revenue has not even placed on record any document to suggest that the reasons recorded have been furnished to the Petitioner. On this ground alone the assessment order impugned herein deserves to be quashed. - HC....