Reasons recorded for reopening of assessment must meet judicial scrutiny

DCIT Vs Reliance Industrial Holdings Pvt Ltd (ITAT Mumbai) In the cases of the reopened assessments first and foremost one has to see the reasons recorded for reopening the assessment, as these are the reasons which give jurisdiction to the Assessing Officer for initiating, and proceedings with, the reassessment. The reasons so recorded must meet judicial scrutiny. Unless this bridge is crossed, there is no occasion to deal with anything else pertaining to the whole process of reassessment. It is well settled in law that reasons, as recorded for reopening the reassessment, are to be examined o...