Held that the reasons recorded by the Assessing Officer for reopening of assessment were replete with various factual misstatements and inaccuracies and silly mistakes. The reasons recorded were based on either non-existent or completely irrelevant facts. In fact, while disposing of the objections of the assessee questioning the validity of the reopening of the assessment, the Assessing Officer had clearly admitted various factual inaccuracies in the recorded reasons. The higher authorities while granting approval under section 151 of the Act had approached the issue in a mechanical manner without verifying the facts. When the Assessing Officer, while disposing of the objections of the assessee had admitted errors committed by him, the Dispute Resolution Panel had fallen into the same error while referring to non-filing of return of tax deducted at source and related transaction as the cause for reopening of assessment, the Dispute Resolution Panel had disposed of the objections of the assessee, being completely oblivious of the factual position, as it had referred to non-filing of return of tax deducted at source and related transactions as the reasons for reopening. The reassessment is bad in law. (AY.2013-14)