Reopening based on assessment record without tangible material is unsustainable

Axis Bank Limited Vs ACIT (Gujarat High court) Gujarat High Court held that re-opening sought on the basis of assessment record without any fresh tangible material is unsustainable in law. Facts- The case of the petitioner was selected for revision u/s. 263 of the Act by the higher authority of then assessing officer i.e. Principal Commissioner of Income Tax and u/s. 143(3) read with Section 263 of the Act, the total income of the petitioner was revised and determined as Rs.122,00,22,24,051/-. The petitioner was then served with the notice u/s. 148 of the Act on 26.03.2021 asking the petitione...