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2015 (2) TMI 104 - ITAT DELHI
Validity of reopening u/s. 148 - certain investigation were carried out by the Directorate of Investigation, Jhandewalan, New Delhi in respect of the bogus / accommodation entries provided by certain individual / companies - Held that:- AO has not applied his mind so as to come to an independent conclusion that he has reason to believe that income has escaped during the year. A mere reference is made to certain information received from the Investigation Wing which was supplied to the assessee vide AO’s letter dated 15.9.2010. In our view the reasons are vague and are not based on any tangible material as well as are not acceptable in the eyes of law. The AO had mechanically issued notices u/s. 148 of the Act, on the basis of information allegedly received by him from the Directorate of Investigation, Jhandewalan, New Delhi. Thus the reopening in the case of the assessee for the asstt. year in dispute is bad in law and deserves to be quashed. - Decided in favour of assessee.