Law of Reopening of assessment under Section 147 of Income Tax Act 1961

Kantibhai Dharamshibhai Narola Vs ACIT (Gujarat High Court)

(i) The Court should be guided by the reasons recorded for the reassessment and not by the reasons or explanation given by the Assessing Officer at a later stage in respect of the notice of reassessment. To put it in other words, having regard to the entire scheme and the purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Offic

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