Reason recorded are without application of mind if for similar reasons no addition been made in earlier Assessment Year

Rajdeep Marketing Private Limited Vs Income Tax Officer (Bombay High Court) HC observed that, If on identical reasons raised for Assessment Year 2012-­13 petitioner’s explanation has been accepted and no addition made, certainly on the same ground, we wonder how an allegation of escapement of income can be made for the subsequent Assessment Years. In our view, the reasons have been recorded without application of mind. FULL TEXT OF THE JUDGMENT/ORDER OF BOMBAY HIGH COURT 1. Petitioner received a notice dated 30th March 2021 under Section 148 of the Income Tax Act, 1961 (the said Act), for ...