Allowing the appeal of the assessee the Tribunal held that as per the recorded reasons by the AO indicated that the assessee is treated as share broker and not mentioned how the figures are arrived. Accordingly the Tribunal held that as the recorded reasons being vague merely on the basis of information received from the office of DIT (Intell CR Inv.) reassessment is held to be bad in law. followed Chhigamal Rajpal v.S.P Chaliha (1971) 79 ITR 603 (SC), Sheo Nath Singh v. ACIT (1971) 82 ITR 147 (SC). (Refer Coronation Agro Industries Ltd. v. Dy.CIT (2017) 390 ITR 464 (Bom.)(HC) (AY. 2009-10)
Dy. CIT v. Setu Securities Pvt. Ltd. (Mum.)(Trib.)(UR)
S. 147 : Reassessment-After the expiry of four years-Client code modifications (CCM)–Recorded reasons being vague merely on the basis of information received from the office of DIT (Intell CR Inv.) reassessment is held to be bad in law. [S. 148]