Revenue not allowed to add reasons to reasons recorded at the time of reopening notice u/s 148

Bakhtawar Construction Co. Pvt. Ltd. Vs DCIT (Bombay High Court) Bombay High Court held that the reopening notice can be sustained only on the basis of the ground mentioned in the reasons recorded. It is not open to the revenue to add and/or supplement later the reasons recorded at the time of reopening notice. Accordingly, reassessment proceedings set aside. Facts- The petitioner received notice u/s. 148 of the Income Tax Act based on the reason that petitioner has gifted a flat to Bezan Chenoy as per the Memorandum of family arrangement and thereby, petitioner has resorted to colorable devic...