Sec. 147 of Income Tax Act, 1961— Re-assessment—The appeal is against the order of reopening under section 147 of the Act, 1961 which was upheld by CIT(A) in appeal. AO made an addition of Rs. 137455/- to the total income of the assessee on account of client code modification and there after determined the total income of the assessee at Rs. 189586/– against the returned income of Rs. 52131/–by passing an order under section 147/143 (3) of the act. The assessee contended that the reasons recorded were mere reasons to suspect and were just to make fishing and roving enquiries, such as no independent enquiry was conducted by the assessing officer before issuing such notice under section 148 and as such the proceedings so, initiated under section 148 was a mere pittance and was liable to be quashed as such. ITAT dismissed the appeal of the assessee holding that “we are of the clear view that there is no infirmity in the reasons recorded by the learned assessing officer and in the reopening of the assessment under section 147 of the act. The assessing officer had tangible material, clear-cut information about the change of client code of assessee by TCG stock broking Ltd, exact nature of the changes are also available, it was also known to him that it is not miss punching or but complete change of all the keys”.—ARUNACHAL PROPERTIES PVT LTD vs. ITO.[2020] 26 ITCD Online 052 (ITAT-DELHI)