Directions of JCIT or CIT cannot only be reason to believe for reopening of assessment

Advocate Akhilesh Kumar Sah Agfa India Pvt. Ltd. Vs. ACIT (ITAT Pune) Procedural formalities for reopening of the assessment under the provisions of the Income Tax Act, 1961 (for short ‘the Act’) have to be followed. Recently, in Agfa India Pvt. Ltd. (now merged with Afga Healthcare India Pvt. Ltd.) vs. ACIT [ITA No. 1020/PUN/2015, decided on 15.09.2017], briefly, the appellant among st other grounds submitted before Pune ITAT that the CIT(A) erred in confirming the action of the Assessing Officer (AO) of re-opening the assessment under section 147 of the Act and the reassessment ...