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2021 (3) TMI 188 - HC - Income TaxReopening of assessment u/s 147 - reasons to believe - HELD THAT:- As the Tribunal has rightly noted, the jurisdiction for the Assessing Officer to resort to Section 147 of the Income Tax Act is crystallized in the Reasons supplied. The Tribunal has rightly, observed that the Reasons only referred to a need to verify the documents and there is no link between the statement that there is a reason to believe that income as escaped assessment with the rest of the Reasons supplied. It is not permissible, as rightly noted by the Tribunal, to add to the Reasons. The contention that there was an information received was not included in the Reasons. The Tribunal has followed the decision of the Jurisdictional High Court in the case of Nivi Trading Limited [2015 (4) TMI 411 - BOMBAY HIGH COURT]. If the Tribunal in these facts and circumstances has found that the reopening of assessment was without jurisdiction based on reading of the Reasons, it cannot be said that any perverse or illegal view has been taken by the Tribunal. No question of law arises. The Appeal is dismissed.
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