Anurag v. ITO (2019) 76 ITR 38 (SN) (Delhi)(Trib.)

S. 147 : Reassessment–Reopening on same issue merely for making fishing or roving inquiries is impermissible in law. [S. 148]

The Tribunal held that, reopening of the assessment could not be permitted for fishing or a roving inquiry, as in the original assessment the AO had gone through all the facts and taken a decision. Notice of reopening u/s. 148 on the same issue was merely for making fishing or roving inquiries which would not permit the requirement of reopening. Hence, reopening is bad in law. (AY. 2010-11)