Validity of reopening of assessment should be judged only with reference to the reasons recorded by the Assessing Officer u/s.148(2)

Rajat Export Import India Pvt. Ltd. Vs. ITO (Delhi HC)– The reasons to believe recorded in writing by the Assessing Officer in the present case have been quoted earlier. They are detailed and show application of mind. The reasons record inferences and conclusions. We wanted to examine the material or evidence on the basis of which conclusions/inferences were drawn. When the record of the Assessing Officer was produced, it was noticed that the documents/ material furnished by the Investigating Wing was not on record and, therefore the order dated 2.12.2011 was passed. Subsequently, on 16....