Section 148- Revenue cannot travel beyond reasons recorded & same cannot be supplemented at the Later stage

Gateway Leaisng Pvt Ltd Vs ACIT (Bombay High Court)

Section 148- Revenue cannot travel beyond reasons recorded & same cannot be supplemented at the Later stage. Reasons which are recorded by the Assessing Officer for re-opening an assessment are the only reasons which can be considered when the formation of the belief is impugned; such reasons cannot be supplemented subsequently by affidavit (s).

The grounds or reasons which led to formation of the belief that income chargeable to tax has escaped assessment must have a mate

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