Reopening invalid if reasons recorded for reopening the assessment are devoid of any application of mind

Shri Niranjan Dass Vs ITO (ITAT Delhi)

All facts when considered with reasons recorded for reopening of the assessment would lead to only one conclusion that the reasons recorded for reopening the assessment are devoid of any application of mind. In our considered opinion, such reopening cannot be upheld. We, accordingly, quash the notice u/s 148 of the Act thereby quashing the assessment order so framed. Since we have quashed the assessment order, we do not find it necessary to dwell into the merits of the case.

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