Reasons are required to be recorded by the AO on valid material and an assessment cannot be reopened on mere assumptions

Weizmann Capital Ltd. Vs ACIT (ITAT Mumbai)- The income, which the Assessing Officer initially formed a reason to believe had escaped assessment, has as a matter of fact, not escaped assessment, it is not open to the Assessing Officer independently to assess some other income. In the present case, the Assessing Officer reopened the assessment for the reason to believe that there is diminution in the value of shares but it is not correct and while making assessment the Assessing Officer had made an assessment on a different ground that the loss

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