The assessing authority cannot act on the dictates of the Commissioner to reopen the concluded assessment

RELEVANT PARAGRAPH 8. The appeal had been admitted to examine the following question of law : (1) Whether, the Tribunal was correct in holding that the Assessing officer had to record his reasons and based on those reasons form his opinion that the income has escaped assessment by relying on two judgements of this Honourable Court in 133 JTJ? 199 and 155 ITR 748 before reopening assessments when Section 147 has been amended by Direct Tax Laws Amendment Act, 1989, w.e.f. from 1.4.1989 by substituting the words “for reasons to be recorded by him in writing is of the opinion* with the words...