Shanti Prime Publication Pvt. Ltd.
Section 68, 147, 148 of IT Act, 1961 —Reassessment — For reopening an assessment under section 148 of the Act, the reasons recorded by the assessing officer should be that of his own and further they should be clear and unambiguous. The reasons should provide link between conclusion and evidence. It is for the assessing officer to form the opinion and to disclose his mind through the reasons recorded, i.e., the assessing officer should form the opinion independently by duly applying his mind on the material available with him, i.e., the AO cannot borrow reasons from any other authority. Janani Infrastructure Pvt. Ltd. Vs. Asstt. CIT (2019) 74 ITR (Trib) 373 (Bangalore)