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 material bearing on the question of escapement of income of the asses...