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2016 (2) TMI 971 - HC - Income TaxReopening of assessment - reasons to believe - addition to income - Held that:- The issue urged by the Revenue stands covered in favour of the assessee by the decision of this court in Ranbaxy Laboratories Ltd. v. CIT [2011 (6) TMI 4 - DELHI HIGH COURT ] which has been followed in CIT v. Software Consultants [2012 (2) TMI 18 - DELHI HIGH COURT ]. In sum, if no addition is made on the basis of the reasons to believe recorded by the Assessing Officer for reopening the assessment under section 148 of the Act, resort cannot be had to Explanation 3 to section 147 of the Act to make an addition on any other issue not included in the reasons to believe for reopening the assessment. - Decided in favour of assessee
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