Reopening u/s 147 without recording specific reasons is invalid

Ravi Gopal Trivedy Vs National-e-Assessment Centre Delhi (ITAT Mumbai)

ITAT Mumbai held that reopening of assessment u/s 147 without recording any specific reasons and without linking the information received from DDIT(Inv) specifically to assessee is invalid and liable to be set aside.

Facts- The assessment of the assessee was reopened by issue of notice u/s. 148 for the reason that certain information was received from DDIT(Inv), Mumbai in the course of investigation in

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