Reopening based on mere AIR Information without Application of Mind is Invalid

Raj Kumar Maheshwari Vs ITO (ITAT Jaipur) The issue under consideration is whether the re-opening of assessment u/s 147 by AO is justified in law? ITAT states that, it is manifest from the reasons recorded by the AO in the assessment order that the AO received the information about the credit card bills payment and further the AO recorded the fact that since the assessee has not filed any return of income, therefore, it is not possible to verify the said transaction and tax liability in this transaction. These reasons recorded by the AO are factually not correct and the formation of belief by ...