Reopening to seek Investigation of facts is not permissible

Sujay Pankajbhai Shah Vs ACIT (ITAT Ahmadabad)

A bare glance of the reasons recorded gives an unflinching impression that powers exercised under section 147 of the Act was to enable the AO to carry out detailed verification of the various aspects of such matter in reference made to the AO herein by the office of Director of Income Tax, Delhi. Thus, it is self-evident that no definite formation of belief towards escapement of income was existing at the time of issuance of notice by the AO. What the AO really intended is to ma

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