For invoking reassessment proceedings, reasons has to be recorded & not conclusions

CA Prarthana Jalan Hon’ble Delhi ITAT has in the case of ACIT V/s M/s Responsible Builders Pvt. Ltd in  ITA No. 2726/Del /2011 has held that it is trite law that in order to determine whether there are reasons to believe that the income got escaped the assessment, one has to look at the reasons recorded by the Assessing Officer before the issuance of notice under Section 148 of the Act. For before invoking the re-assessment proceedings the A,O has to record the reason as to how income has escaped assessment and not conclusions. In the case the assessee was engaged in the business of inv...