Reopening based on vague and non-speaking reasons is reopening without jurisdiction

Advertisement Sunil Agarwal Vs ITO (ITAT Delhi) We find that there is no allegation in the reasons recorded that there is failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment u/s 147 of the Act, the notice issued u/s. 148 of the Act after a period of four years from end of assessment year in case where assessment has been framed u/s. 147/143(3) of the Act is illegal and invalid. It is also noted that the reasons recorded are vague and non-speaking and reflect complete non-application of mind much less independent “application of mind�...