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2012 (4) TMI 613 - ITAT DELHIReopening of assessment - Held that:- Reopening in this case is bad in law. The reasons recorded in the present case are also scanty and vague. There is no reference to any document or statement except mentioned of supplementary list of beneficiaries. This can not be regarded as material or evidence that prima facie shows or establishes escapement of income. It is apparent that the Assessing Officer did not apply his own mind to the information and examine the basis of the information. Assessing Officer has accepted the information in a mechanical manner. Assessing Officer did not verify the correctness of the information received by him but merely accepted the truth of the vague information in a mechanical manner. The Assessing Officer has not even recorded his satisfaction about the correctness or otherwise of the information or his satisfaction that a case has been made out for issuing a notice u/s. 148 of the Act. Thus, in our considered opinion, the Assessing Officer has clearly substituted form for substance and therefore the Assessing Officer‘s action is not in accordance with law
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