Sec. 147 & 148 of Income Tax Act, 1961 — Reassessment - The petitioner challenged a notice of reopening of assessment in question. High Court disposed of the writ petition of the assessee holding that “When the reasons do not record any other element of income chargeable to tax having escaped assessment, it would not possible for the revenue to bring such element into consideration either through affidavit or oral arguments. We have examined the reasons and find that these reasons simply do not provide the live link to the formation of belief by the Assessing Officer that assessee's income chargeable to tax has escaped assessment. In the result, impugned notice is set aside”. - ASSET RECONSTRUCTION COMPANY INDIA PVT. LTD. V/s DEPUTY CIT - [2020] 424 ITR 715 (BOM)