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 National Stock Exchange Ltd with regard to the issue of Client Code Modification in the case of few brokers and based on a ...