Reopening on incoherent reasons not valid u/s 147

Brief of the Case Delhi High Court held In the case of Sabharwal Properties Industries Pvt. Ltd. vs. ITO that the reasons recorded for reopening are totally incoherent. In fact, a plain reading of reasons, gives rise to doubts whether some lines have gone missing or some punctuation marks have been left out. Grammatically also the reasons recorded make little sense. It is well settled that the reasons recorded for reopening the assessment have to speak for themselves. They have to spell out that (i) there was a failure of the Assessee to disclose fully and truly all the material facts necessa...