Validity of reopening of assessment has to be determined on the basis of reasons for reopening

In the present case, the submission of the assessee before the Tribunal, as recorded in paragraph 3 of the impugned order, is that the only reason which was given by the Assessing Officer for initiating reassessment proceedings was that the property was sold by the assessee for Rs.31 lacs but its value for the purpose of stamp duty as per the circle rate was Rs.82.54 lacs, resulting in an escapement of income of Rs.51.54 lacs. The notice under Section 148 was available on the record of the Tribunal. The Tribunal also had the benefit of perusing the income tax re

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