AO cannot reopen the case without bringing something new on record

DCIT Vs M/s. Idea Cellular Ltd. (ITAT Mumbai)

During the original assessment proceedings, the AO had made inquiries about roaming charges,that the assessee had detailed submissions in that regard,that being satisfied with the explanation of the assessee,he passed an order u/s. 143(3) of the Act,that during the original assessment he allowed the roaming charges and did not invoke the provisions of section 40(a)(ia)of the Act,that in the notice issued u/s.148 of the Act, the basis of reopening was applicability of section 40(a)(ia)of the Act with regard to roaming ch

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