Where a issue was not scrutinized under Section 143(3), however queries were raised before issuance of Notice under Section 148 and the Petitioner responded to the queries and furnished all the relevant details, there is no fault in Petitioner’s part and the reopening is impermissible.

Where Reasons for reopening mentions that Requisite details were not filed by the Petitioner, however the same were duly filed by the Petitioner the reopening is sought to be carried out on incorrect facts and the same is impermissible.