Section 148 Reopening based on incorrect facts & reasons is invalid: ITAT Delhi

Ganesh Ganga Investments Pvt. Ltd. Vs ITO (ITAT Delhi) ITAT Delhi held that reopening of assessment under section 148 of the Income Tax Act based on incorrect facts and incorrect recording of reasons is invalid and bad-in-law. Accordingly, reopening is liable to be quashed. Facts- A search/survey operation u/s. 132/133A of the Income Tax Act, 1961 was conducted by the Investigation Wing at the business and residential premises of Shri Himanshu Verma. During the course of inquiry made by the Investigation Wing, it also came to the notice that Shri Himanshu Verma was engaged in the business of p...