Recorded reasons for reopening can neither be improved nor substituted by an affidavit

B.U. Bhandari Autolines Pvt. Ltd. Vs ACIT (Bombay High Court) Bombay High Court held that issue of reopening of assessment has to be tested only on the basis of the reasons recorded, which reasons can neither be improved upon nor substituted by an affidavit or oral submissions. Facts- The Petitioner filed its return of income, which was processed under Section 143(1) of the Income Tax Act, 1961 (“the Act”) for the assessment year 2016-17. The assessing officer subsequently issued a notice under Section 148 of the Act dated 30.03.2021 seeking to reopen the assessment for the assessment year...