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2016 (9) TMI 1591 - AT - Income TaxReopening of assessment u/s 147 - validity of reasons to believe - non independent application of mind by AO - HELD THAT:- After going through the reasons recorded by the AO - 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 - Reasons are vague and are not based on any tangible material as well as are not acceptable in the eyes of law. AO has mechanically issued notice u/s. 148 of the Act, on the basis of information allegedly received by him from the Directorate of Income Tax (Investigation), 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.
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