Reopening of assessment u/s 147 without cogent reasoning is untenable

Ramchandra Dashrath Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that reopening of assessment under section 147 of the Income Tax Act without iota of evidence or any cogent reasons is unsustainable and liable to be quashed.

Facts- The assessee is a partnership firm engaged as fruit merchant and commission agent for fruits in the APMC market. The assessee is also engaged in trading activities which were not reflected in the financial statement and in the income tax records.

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