Sharvah Multitrade Compant P Ltd. v. ITO

134 Taxmann.com 134High Court#5496 most cited

What is Sharvah Multitrade Compant P Ltd. v. ITO authority for?

Approval for reassessment under section 151 of the Income Tax Act, 1961, requires the issuing authority to apply their mind to the facts and not grant approval mechanically. A blank subsequent column in the approval form for section 151 may not invalidate the approval if the substance of the reassessment is considered.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2024.

Also referred to as

Sharvah Multitrade Company P Ltd. v. ITO · Section 151 · Section 147 · PCIT approval · mechanical approval · income escaped assessment · validity of approval

Sections most often in play

Section 115JBSection 147Section 151Section 69CSection 133ASection 149Section 153CSection 143(3)

Issues it is cited on

section 147ofsection 40a(2)(a)full and true disclosurebeyond four yearscircular tradingsection 151(2)mere change of opinioninitial assessment yearfresh tangible materialamalgamationsection 10aacomputer software

Judgments citing Sharvah Multitrade Compant P Ltd. v. ITO

DCIT CC -4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

ITA 3614/MUM/2023[2018-19]Status: DisposedITAT Mumbai24 Jul 2024AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 10ASection 115JSection 143(3)Section 147Section 149Section 151Section 69C

…paragraph and submitted that the Ld. PCIT has granted the approval mechanically without reading above paragraph. The Ld. counsel for the assessee relied on the decision of the Hon'ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT 134 Taxmann.com 134 (Bombay). He also relied on the decision of the Hon'ble Bombay High Court in the case of Vodafone India Ltd. v. DCIT Writ Petition No. 2108 of 2023. 12.2 On the contrary, the Ld. DR submitted that in the column for approval u/s 151 of the Act, it is clearly mentioned that income escaped was more than Rs. 1 lakh and in the relevant column…

DCIT CC -4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

ITA 3610/MUM/2023[2020-21]Status: DisposedITAT Mumbai24 Jul 2024AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 10ASection 115JSection 143(3)Section 147Section 149Section 151Section 69C

…paragraph and submitted that the Ld. PCIT has granted the approval mechanically without reading above paragraph. The Ld. counsel for the assessee relied on the decision of the Hon'ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT 134 Taxmann.com 134 (Bombay). He also relied on the decision of the Hon'ble Bombay High Court in the case of Vodafone India Ltd. v. DCIT Writ Petition No. 2108 of 2023. 12.2 On the contrary, the Ld. DR submitted that in the column for approval u/s 151 of the Act, it is clearly mentioned that income escaped was more than Rs. 1 lakh and in the relevant column…

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

ITA 3606/MUM/2023[2014-15]Status: DisposedITAT Mumbai24 Jul 2024AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Dr. Kishor Dhule, CIT-DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 69C

…High the assessee relied on the decision of the Hon’ble Bombay High the assessee relied on the decision of the Hon’ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT Sharvah Multitrade Company (P.) Ltd. v. IT Court in the case of 134 Taxmann.com 134 (Bombay) 134 Taxmann.com 134 (Bombay). He also relied on the decision of . He also relied on the decision of M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 the Hon’ble Bo…

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

ITA 3605/MUM/2023[2015-16]Status: DisposedITAT Mumbai24 Jul 2024AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Dr. Kishor Dhule, CIT-DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 69C

…High the assessee relied on the decision of the Hon’ble Bombay High the assessee relied on the decision of the Hon’ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT Sharvah Multitrade Company (P.) Ltd. v. IT Court in the case of 134 Taxmann.com 134 (Bombay) 134 Taxmann.com 134 (Bombay). He also relied on the decision of . He also relied on the decision of M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 the Hon’ble Bo…

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

ITA 3603/MUM/2023[2016-17]Status: DisposedITAT Mumbai24 Jul 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Dr. Kishor Dhule, CIT-DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 69C

…High the assessee relied on the decision of the Hon’ble Bombay High the assessee relied on the decision of the Hon’ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT Sharvah Multitrade Company (P.) Ltd. v. IT Court in the case of 134 Taxmann.com 134 (Bombay) 134 Taxmann.com 134 (Bombay). He also relied on the decision of . He also relied on the decision of M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 the Hon’ble Bo…

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

The appeal of the Revenue is dismissed

ITA 3602/MUM/2023[2017-18]Status: DisposedITAT Mumbai24 Jul 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 10ASection 115JSection 143(3)Section 147Section 149Section 151Section 69C

…paragraph and submitted that the Ld. PCIT has granted the approval mechanically without reading above paragraph. The Ld. counsel for the assessee relied on the decision of the Hon'ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT 134 Taxmann.com 134 (Bombay). He also relied on the decision of the Hon'ble Bombay High Court in the case of Vodafone India Ltd. v. DCIT Writ Petition No. 2108 of 2023. 12.2 On the contrary, the Ld. DR submitted that in the column for approval u/s 151 of the Act, it is clearly mentioned that income escaped was more than Rs. 1 lakh and in the relevant column…

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

ITA 3491/MUM/2023[2014-15]Status: DisposedITAT Mumbai24 Jul 2024AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

Section 10ASection 115JSection 143(3)Section 147Section 149Section 151Section 69C

…paragraph and submitted that the Ld. PCIT has granted the approval mechanically without reading above paragraph. The Ld. counsel for the assessee relied on the decision of the Hon'ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT 134 Taxmann.com 134 (Bombay). He also relied on the decision of the Hon'ble Bombay High Court in the case of Vodafone India Ltd. v. DCIT Writ Petition No. 2108 of 2023. 12.2 On the contrary, the Ld. DR submitted that in the column for approval u/s 151 of the Act, it is clearly mentioned that income escaped was more than Rs. 1 lakh and in the relevant column…

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

ITA 3474/MUM/2023[2015-16]Status: DisposedITAT Mumbai24 Jul 2024AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Dr. Kishor Dhule, CIT-DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 69C

…High the assessee relied on the decision of the Hon’ble Bombay High the assessee relied on the decision of the Hon’ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT Sharvah Multitrade Company (P.) Ltd. v. IT Court in the case of 134 Taxmann.com 134 (Bombay) 134 Taxmann.com 134 (Bombay). He also relied on the decision of . He also relied on the decision of M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 the Hon’ble Bo…

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

ITA 3473/MUM/2023[2016-17]Status: DisposedITAT Mumbai24 Jul 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 10ASection 115JSection 143(3)Section 147Section 149Section 151Section 69C

…paragraph and submitted that the Ld. PCIT has granted the approval mechanically without reading above paragraph. The Ld. counsel for the assessee relied on the decision of the Hon'ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT 134 Taxmann.com 134 (Bombay). He also relied on the decision of the Hon'ble Bombay High Court in the case of Vodafone India Ltd. v. DCIT Writ Petition No. 2108 of 2023. 12.2 On the contrary, the Ld. DR submitted that in the column for approval u/s 151 of the Act, it is clearly mentioned that income escaped was more than Rs. 1 lakh and in the relevant column…

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

ITA 3472/MUM/2023[2017-18]Status: DisposedITAT Mumbai24 Jul 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 10ASection 115JSection 143(3)Section 147Section 149Section 151Section 69C

…paragraph and submitted that the Ld. PCIT has granted the approval mechanically without reading above paragraph. The Ld. counsel for the assessee relied on the decision of the Hon'ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT 134 Taxmann.com 134 (Bombay). He also relied on the decision of the Hon'ble Bombay High Court in the case of Vodafone India Ltd. v. DCIT Writ Petition No. 2108 of 2023. 12.2 On the contrary, the Ld. DR submitted that in the column for approval u/s 151 of the Act, it is clearly mentioned that income escaped was more than Rs. 1 lakh and in the relevant column…

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAXCENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed whereas

ITA 3471/MUM/2023[2020-21]Status: DisposedITAT Mumbai24 Jul 2024AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Dr. Kishor Dhule, CIT-DR
Section 10ASection 115JSection 143(3)Section 147Section 149Section 151Section 69C

…paragraph and submitted that the Ld. PCIT has granted the approval mechanically without reading above paragraph. The Ld. counsel for the assessee relied on the decision of the Hon'ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT 134 Taxmann.com 134 (Bombay). He also relied on the decision of the Hon'ble Bombay High Court in the case of Vodafone India Ltd. v. DCIT Writ Petition No. 2108 of 2023. 12.2 On the contrary, the Ld. DR submitted that in the column for approval u/s 151 of the Act, it is clearly mentioned that income escaped was more than Rs. 1 lakh and in the relevant column…

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

ITA 3470/MUM/2023[2021-22]Status: DisposedITAT Mumbai24 Jul 2024AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Dr. Kishor Dhule, CIT-DRFor Respondent: Mr. Rakesh Joshi
Section 143(3)Section 69C

…High the assessee relied on the decision of the Hon’ble Bombay High the assessee relied on the decision of the Hon’ble Bombay High Court in the case of Sharvah Multitrade Company (P.) Ltd. v. IT Sharvah Multitrade Company (P.) Ltd. v. IT Court in the case of 134 Taxmann.com 134 (Bombay) 134 Taxmann.com 134 (Bombay). He also relied on the decision of . He also relied on the decision of M/s Sanman Trade Impex Ltd. M/s Sanman Trade Impex Ltd. ITA Nos. 3491, 3474, 3473, 3472 3471, 3470/MUM/2023 3471, 3470/MUM/2023 3606, 3605, 3603, 3602, 3614 & 3610, 3606, 3605, 3603, 3602, 3614 & 3610, 3601/MUM/2023 the Hon’ble Bo…

DCIT CC 4(4), MUMBAI, MUMBAI vs. ASPEN INTERNATIONAL PRIVATE LIMITED, MUMBAI

In the result, all the appeals of the assessee are allowed

ITA 3594/MUM/2023[2014-15]Status: DisposedITAT Mumbai05 Apr 2024AY 2014-15
Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon'ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available to the ld AO and it should not be don…

DCIT CC 4(4), MUMBAI, MUMBAI vs. ASPEN INTERNATIONAL PRIVATE LIMITED, MUMBAI

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 3593/MUM/2023[2015-16]Status: DisposedITAT Mumbai05 Apr 2024AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S RIFAUR RAHMAN (Accountant Member)

Section 133ASection 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon’ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. M/s. Aspen International Pvt. Ltd. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available t…

DCIT CC 4(4), MUMBAI, MUMBAI vs. ASPEN INTERNATIONAL PRIVATE LIMITED, MUMBAI

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 3591/MUM/2023[2016-17]Status: DisposedITAT Mumbai05 Apr 2024AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S RIFAUR RAHMAN (Accountant Member)

Section 133ASection 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon’ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. M/s. Aspen International Pvt. Ltd. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available t…

DCIT CC 4(4), MUMBAI, MUMBAI vs. ASPEN INTERNATIONAL PRIVATE LIMITED, MUMBAI

In the result, all the appeals of the assessee are allowed

ITA 3589/MUM/2023[2017-18]Status: DisposedITAT Mumbai05 Apr 2024AY 2017-18
Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon'ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available to the ld AO and it should not be don…

ASPEN INTERNATIONAL PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, all the appeals of the assessee are allowed

ITA 3469/MUM/2023[2014-15]Status: DisposedITAT Mumbai05 Apr 2024AY 2014-15
Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon'ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available to the ld AO and it should not be don…

ASPEN INTERNATIONAL PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 3468/MUM/2023[2015-16]Status: DisposedITAT Mumbai05 Apr 2024AY 2015-16
Section 133ASection 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon’ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. M/s. Aspen International Pvt. Ltd. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available t…

ASPEN INTERNATIONAL PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 3467/MUM/2023[2016-17]Status: DisposedITAT Mumbai05 Apr 2024AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S RIFAUR RAHMAN (Accountant Member)

Section 133ASection 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon’ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. M/s. Aspen International Pvt. Ltd. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available t…

ASPEN INTERNATIONAL PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE-4(4), MUMBAI, MUMBAI

In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed

ITA 3466/MUM/2023[2017-18]Status: DisposedITAT Mumbai05 Apr 2024AY 2017-18
Section 133ASection 143(3)Section 147Section 148Section 149Section 151Section 69C

…e without applying his own mind. Ld. PCIT has also accorded approval U/s 151 of the Act based on the reasons recorded by the AO without ascertaining the actual facts of the case. Hon’ble Bombay High Court in case of Sharvah Multitrade Compant P Ltd. Vs. ITO ( 134 Taxmann.com 134) dealt with similar case and held that reassessment initiated based on reasons recorded on irrelevant facts and without application of mind cannot survive. M/s. Aspen International Pvt. Ltd. 7. This, in our considered opinion, it is against the settled principles of law, as reopening of an assessment is an extraordinary power available t…

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