Jurisdictional Condition Must Be Satisfied to Justify Notice for Reopening

HDFC Bank Ltd. Vs ACIT (Bombay High Court) Bombay high court exposing serious flaw in reopening under section 148 in HDFC case (significance of tangible material for formulation of valid belief , fatal impact of difference  in the  reasons recorded on file and reasons placed for statutory  approval  under section 151 etc. “30. The position which thus emerges is that the assessee had placed all the relevant facts before the AO. Specific queries were raised as regards the allowability of deduction under section 36(1) (viia). Upon consideration of the explanation furnished by the asses...