Reopening invalid if no mention of failure on the part of assessee in reasons recorded

Soul Jewels Vs DCIT (ITAT Mumbai)

We find that assessee is a partnership firm engaged in the business of trading in diamonds. The original assessment was completed for the A.Y.2007-08 u/s.143(3) r.w.s. 153A of the Act determining the total income at Rs.56,34,520/- vide order dated 27/12/2011. This assessment was sought to be reopened by issue of notice u/s.148 of the Act on 29/03/2014 which was served on the assessee on the same day. In response to the said notice, the assessee already had filed written reply on 16/04/2014 stating that the return of inc

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