Reopening u/s 148 fails as was based on material which no longer exists as being legally incorrect

Citicorp Trustee Company Ltd. Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that the material/information on which AO have re-opened the assessment is no longer existing being legally incorrect. Hence, action of AO to have issued notice of re-opening of assessment u/s 148 of the Act itself fails.

Facts- The assessee is a company incorporated in the United Kingdom. The assessee company acted as a trustee for bond issuance in the capital markets M/s. Bharat Forge Ltd which had issu

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