Reasons recorded cannot be substituted at a later point in time by subsequent evidences

Red Hat India Pvt. Ltd. Vs DCIT (ITAT Mumbai) From the bare reading of the proviso to section 147 of the Act, it is mandatory on the part of the ld AO to duly mention in the reasons recorded itself as to whether there is any failure on the part of the assessee in disclosing fully and truly all material facts necessary for the assessment. In the instant case, from the reasons recorded (reproduced hereinabove), it could be seen that there is absolutely no mention of any failure on the part of the assessee in disclosing fully and truly all material facts necessary for the assessment during the or...