Held that the Assessing Officer had recorded incorrect, wrong and non-existing reasons for reopening the assessment and failed to verify the veracity of the information received from the Investigation Wing. The Commissioner also had given approval in a mechanical manner. Therefore, the reopening of the assessment was invalid. (AY. 2010-11)
R.S. Shares and Securities Ltd. v. ITO (2021) 86 ITR 269 (SMC) (Delhi)(Trib.)
S. 147 : Reassessment-Information from investigation Wing-Client code modification-Recording of incorrect and wrong facts-Mechanical approval-Reassessment was not valid. [S. 148, 151]