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Sec. 147 of Income Tax Act, 1961— Reassessment—Reopening of assessment invalid as AO has recorded incorrect and wrong reasons for reopening of the assessment and did not apply his mind to the facts of the case before recording reasons for reopening of the assessment and the AO has also failed to verify the information received from the Investigation Wing before recording the reasons for reopening of the assessment and even the sanctioning authority has not applied its mind to the conclusion drawn by the AO based on specific material on record which clearly revealed that reasons recorded by the AO are wrong, incorrect and based on no evidence, therefore, it is a clear case of non-application of mind by the AO before recording reasons for reopening of the assessment — ARORA/SAPRA, S.N. Vs. ITO [2020] 204 TTJ 137 (ITAT-DELHI)