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“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

Vijit Singh, Jaipur vs. ITO Ward 3(2) Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1246/JPR/2025[2009-10]Status: DisposedITAT Jaipur17 Nov 2025AY 2009-10
For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT
Section 147Section 234ASection 250

Satisfaction or application of mind by the Add. CIT and Pr. CIT: At\nthe very outset it is submitted that on perusal of the reason recorded and\napproval u/s 151 by the competent authority it is clearly proved that they in the\nsatisfaction the ld. Pr.CIT has mentioned only that ... nCIT has given the approval and satisfaction in the mechanical manner, he has\nnot recorded his own satisfaction. As on perusal of the reason recorded and\napproval u/s 151 by the without competent authority it is clearly proved that\nthey have not applied the mind on the reasons recorded they

Pavitar Singh, Jagadhri, Yamunanagar vs. Commissioner of Income Tax, Chandigarh

In the result, appeal of the Assessee is dismissed

ITA 653/CHANDI/2025[2010-11]Status: DisposedITAT Chandigarh17 Nov 2025AY 2010-11

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita No. 653/Chd/2025 "नधा"रण वष" / Assessment Year : 2010-11 Pavitar Singh, Ito, बना 188, Vuillage Satgoli, Nwr-W-(65)(95) Bhagu Majra, Chandigarh म Jadadhri, Yamunanagar Vs. "थायी लेखा सं./Pan No: Bteps4094J अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Sh. Rachit Goyal, CAFor Respondent: Sh. Vinod Kumar Chaudhary, JCIT, Sr. DR
Section 142(1)Section 271(1)(b)Section 271(1)(c)

Assessing Officer, the Assessee preferred an appeal before the CIT(A). The Ld. CIT(A) had dismissed the assessee's appeal for the reasons recorded in para 5.2.2. of his order which is to the following effect. 4 “5.2.2. In addition to the above arguments, the appellant has submitted

Geeta Sharma, Sunam vs. ITO, Sunam

In the result, appeal of the assessee is allowed

ITA 491/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh17 Nov 2025AY 2015-16
For Appellant: Sh. Rajiv Saldi, CAFor Respondent: Sh. Prem Singh, Addl. CIT
Section 142(1)Section 143(2)Section 148Section 149

have patiently heard at length the arguments of both the\nparties in this regard and have also carefully perused the\ncontents of the reasons recorded for reopening the case of the\nassessee placed before us at Paper Book page No. 15. We find\nmerit in the contention of Ld.Counsel ... available with the\nAO could not have lead to the formation of belief of escapement\nof any income at all.\n18. As per the reasons recorded by the AO, the belief of escapement\nof income is based on the information of cash deposits in the\nbank account of the assessee

Jamyang Khyentse Yeshi, Kangra, Himachal Pradesh vs. ACIT, DCIT, C.R. Building, Chandigarh

The appeal of the assessee is partly allowed

ITA 604/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh17 Nov 2025AY 2013-14

Bench: The Ld. Cit(A). The Ld. Cit(A), After Calling For A Remand Report Under Rule 46A, Recorded The Following Findings (Para 5.1 To 5.5 Of The Appellate Order):

For Appellant: Shri Nitin Kanwar, Advocate (Virtual)For Respondent: Shri Prem Singh, Addl. CIT, Sr. DR
Section 133(6)Section 147Section 148Section 69A

email id registered on the IT portal was that of the previous consultant, who never informed the same to the assessee. Also, No reasons recorded and approval from competent authority before issue of notice u/s 148 were provided to the assessee. No information was available with the Ld.AO

Goodhope Tie-Up Pvt. Ltd., Kolkata vs. I.T.O., Ward - 1(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 942/KOL/2025[2013-2014]Status: DisposedITAT Kolkata17 Nov 2025AY 2013-2014

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2013-14 Goodhope Tie-Up Pvt. Ltd. …….................................................……….……Appellant 19, B. B. Ganguly Street, Kol-700012. [Pan: Aaecg0206H] Vs. Ito, Ward-1(1), Kolkata.………..…………………………...……...…..…..Respondent Appearances By: Shri Amit Agarwal, Advocate, Appeared On Behalf Of The Appellant. Dr. Anup Biswas, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 17, 2025 Order Per Rajesh Kumar: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 04.03.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As The "Ld. Cit(A)") Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As The "Act"].

Section 143(1)Section 143(3)Section 147Section 148Section 250

disclosed all the material facts relating to the transactions carried out by the assessee and there is no adverse finding mentioned in the said reasons recorded by the Assessing Officer that there is any failure on the part of the assessee to fully disclose the material facts necessary ... assessment has been re-opened beyond 4 years from the end of relevant assessment year. We further find that the AO in the reasons recorded has not mentioned about the failure on the part of the assessee to disclose fully and truly the facts necessary for assessment of income

Income Tax Officer Ward 1(1), Faridabad vs. Bhikshu Portfolio Private Limited, Faridabad

ITA 4252/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

entries amounting to Rs.1,42,50,989/- in contrast to alleged transaction of 35,00,000 for the year under consideration stated as per reasons recorded.” vii) The appellant also submits that option to seek video conference was not allowed. viii) The appellant submits that in response to show cause ... speaking manner. 5.15.1. The appellant has assailed the proceedings of reopening u/s 147 r.w.s. 148 on different technical grounds, particularly citing inconsistency in the ‘reasons recorded for reopening’. The appellant has cited that;- “..no categorical reference of alleged information found during the course of search conducted on Sh. Himanshu Verma

Income Tax Officer Ward 1(1), Faridabad vs. Bhikshu Portfolio Private Limited, Faridabad

ITA 4251/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Nov 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

entries amounting to Rs.1,42,50,989/- in contrast to alleged transaction of 35,00,000 for the year under consideration stated as per reasons recorded.” vii) The appellant also submits that option to seek video conference was not allowed. viii) The appellant submits that in response to show cause ... speaking manner. 5.15.1. The appellant has assailed the proceedings of reopening u/s 147 r.w.s. 148 on different technical grounds, particularly citing inconsistency in the ‘reasons recorded for reopening’. The appellant has cited that;- “..no categorical reference of alleged information found during the course of search conducted on Sh. Himanshu Verma

Income Tax Officer Ward 1(1), Faridabad vs. Bhikshu Portfolio Private Limited, Faridabad

ITA 4207/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Nov 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

entries amounting to Rs.1,42,50,989/- in contrast to alleged transaction of 35,00,000 for the year under consideration stated as per reasons recorded.” vii) The appellant also submits that option to seek video conference was not allowed. viii) The appellant submits that in response to show cause ... speaking manner. 5.15.1. The appellant has assailed the proceedings of reopening u/s 147 r.w.s. 148 on different technical grounds, particularly citing inconsistency in the ‘reasons recorded for reopening’. The appellant has cited that;- “..no categorical reference of alleged information found during the course of search conducted on Sh. Himanshu Verma

Income Tax Officer, Faridabad vs. Bhikshu Portfolio Private Limited, Faridabad

ITA 4206/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Nov 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

entries amounting to Rs.1,42,50,989/- in contrast to alleged transaction of 35,00,000 for the year under consideration stated as per reasons recorded.” vii) The appellant also submits that option to seek video conference was not allowed. viii) The appellant submits that in response to show cause ... speaking manner. 5.15.1. The appellant has assailed the proceedings of reopening u/s 147 r.w.s. 148 on different technical grounds, particularly citing inconsistency in the ‘reasons recorded for reopening’. The appellant has cited that;- “..no categorical reference of alleged information found during the course of search conducted on Sh. Himanshu Verma

Income Tax Officer, Faridabad vs. Bhikshu Portfolio Private Limited, Faridabad

ITA 4205/DEL/2025[2013]Status: DisposedITAT Delhi17 Nov 2025

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 132Section 132(4)Section 147

entries amounting to Rs.1,42,50,989/- in contrast to alleged transaction of 35,00,000 for the year under consideration stated as per reasons recorded.” vii) The appellant also submits that option to seek video conference was not allowed. viii) The appellant submits that in response to show cause ... speaking manner. 5.15.1. The appellant has assailed the proceedings of reopening u/s 147 r.w.s. 148 on different technical grounds, particularly citing inconsistency in the ‘reasons recorded for reopening’. The appellant has cited that;- “..no categorical reference of alleged information found during the course of search conducted on Sh. Himanshu Verma

Vedanta Ltd (Earlier Known As Madras Aluminium Co. Ltd.), Gurgaon vs. ACIT, Circle- 26(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2406/DEL/2019[2011-12]Status: DisposedITAT Delhi17 Nov 2025AY 2011-12

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

For Appellant: S/Shri Ravi Sharma & Jaskaran SinghFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 143(3)Section 147Section 148Section 80I

been reopened in the instant case after more than four years from the end of relevant assessment year. The relevant excerpts from the reasons recorded for reopening assessment are reproduced herein below: “The assessment in this case for A.Y. 2011-12 was completed ... assessee to disclose fully and truly all material facts necessary for his assessment in the return of income for that assessment year. From the reasons recorded by the AO for reopening the assessment it is lucid that the conditions set out by the first proviso to section

Principal Commissioner of Income Tax 5 Kolkata vs. Manoj Jain

ITAT/294/2024HC Calcutta14 Nov 2025

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 147Section 148

Notice u/s 148 dated 28.03.2017 was unsigned by referring to page no 202 which is the copy of said notice. iii) That the reasons recorded by AO, Ward-35(4), Kolkata whereas the notice was issued by different AO. 5.1. The Ld. A.R drew our attention to the copy

The Principal Commissioner of Income Tax 2 Kolkata vs. Boothnath Vintrade Private Limited

In the result, the appeal of the assessee is allowed

ITAT/297/2024HC Calcutta14 Nov 2025

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 147Section 148

satisfy the basic criteria of independent application of mind on the material supplied by the Investigation Wing, Kolkata. It is evident from the reasons recorded by the Ld. AO that the report supplied by the DCIT (Investigation), Kolkata not even verified by him and accordingly, the justification for initiating proceedings ... evidence in support thereof and without any independent application of mind on the issue. It is an inalienable principle of law that the reasons recorded u/s. 148 of the Act should be based on credible material which must have a live link or nexus with the belief that there

Jayendrabhai Kantilal Patel, Vadodara vs. The ITO, Ward-1(2)(4), Vadodara

In the result, the appeal filed by the assessee is allowed

ITA 1732/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad14 Nov 2025AY 2011-12

Bench: DR. BRR KUMAR (Vice President), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri M K Patel, AdvocateFor Respondent: Shri Rohit Aasudani, Sr. DR
Section 143(3)Section 55A

nature of the asset and other relevant circumstances, it is necessary so to do. Sub-clause(i) of clause (b) also for the same reasons recorded above, would have no bearing on the fair market value as on 1.4.1981. The Assessing Officer had not resorted to sub- clause

Neetu Hurkat, Pali vs. Principal Commissioner of Income Tax Ahmedabad-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 957/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad14 Nov 2025AY 2016-17
For Appellant: \nShri Javed Khan, ARFor Respondent: \nShri Alpesh Parmar, CIT. DR
Section 10Section 143(2)Section 147Section 148Section 263

Reconstruction Company Ltd. to M/s Toyam\nIndustries Ltd.\n6.\nWe have carefully considered the rival submissions and perused the\nmaterials available on record.\nThe reasons recorded on 31.01.2022 by the Assessing Officer for the\nreopening of assessment u/s 148 of the Act are as under:-\n\"2. Brief details ... credits u/s 68 of the Act. Therefore, the order of\nthe A.O. is erroneous which caused loss of revenue.\n10.\nOn going through the reasons recorded by the Assessing Officer, the\nshow-cause notice issued by the Ld. PCIT and the relevant order of the Ld.\nPCIT, we find that

Ram Kishan, Delhi vs. ITO Ward-60(5), Delhi

The appeal is allowed

ITA 5721/DEL/2024[2011-12]Status: DisposedITAT Delhi14 Nov 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2011-12 Ram Kishan, Vs. Ito, H.No.124, 1St Floor, Ward-60(5), Kala Vihar Cghs Ltd., New Delhi. Mayur Vihar Ph.I, Delhi – 110 091. Pan: Ahapc1442P (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate; Ms Uma Upadyay, Ca; & Shri Aditya Garg, Ar Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Pronouncement : 14.11.2025 Order

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 139Section 142Section 143(1)Section 143(3)Section 147Section 148

issues:- A. The reopening is barred by limitation as being beyond 4 years, is covered by Proviso to Section 147 of the Act. B. Reasons recorded are contrary to facts thus a clear case of non- application of mind. C. No Notice ... fully and truly all material facts necessary for his assessment, for that assessment year. However, as per the copy of Annexure A, being the reasons recorded u/s 147 of the Act, there are no such averments in the reasons. In the present case, the assessee has filed the return

Guljar, Saharanpur vs. Income Tax Officer, Ward-3(5), Saharanpur

In the result, the appeal of the assessee in ITA No

ITA 3797/DEL/2024[2009-10]Status: DisposedITAT Delhi14 Nov 2025AY 2009-10

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Ankit Gupta, Adv [through VC]For Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(3)Section 147Section 148Section 151Section 68

which is illegal bad in law and without jurisdiction. 5. That, the NFAC has failed to appreciate that no addition was made on the reason recorded, hence the reassessment order passed and alleged addition made is illegal, bad in law and without jurisdiction. 6. That the NFAC has erred ... counsel for the assessee vehemently contested the reassessment proceedings u/s 147 of the Income-tax Act, 1961 [the Act, for short] and the reasons recorded by the Assessing Officer for reopening the assessment are flawed and invalid. 4. Briefly stated the facts of the case are that the assessee filed

Narendra Kumar Makhija, Kota vs. PCIT, Udaipur

ITA 605/JPR/2025[2018-19]Status: DisposedITAT Jaipur13 Nov 2025AY 2018-19

Bench: Learned Cit(A). Said Appeal Is Pending Before Learned Cit(A), As Claimed By The Appellant.

For Appellant: Shri B.L. Bhojwani, C.AFor Respondent: Mrs. Alka Gautam, CIT
Section 263Section 68

aside. 16. On the other hand, Learned DR for the department has defended the impugned order passed by Learned PCIT for the reasons recorded therein, 11 Narendra Kumar Makhija, Kota. and contended that there is no illegality or irregularity in the impugned order whereby the Assessing Officer has been issued ... that Learned PCIT himself did not conduct any enquiry into the matter before setting aside the assessment order on the opinion and for the reasons, recorded therein. There is no explanation in this regard from the side of the department. Is it not a case of a view or opinion

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. Konark Rajhans Estate Private Limited, Panchkula

In the result, the appeal of the revenue stands dismissed

ITA 805/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh13 Nov 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 805/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2011-12 Acit M/S Konark Rajhans Estate Private Limited Panchkula Circle बनाम/ Vs. Nh 73, Village Kot Extension-Ii, Sector 14, Panchkula. Panchkula. "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeck-2405-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Manav Bansal (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Sh. Parikshit Aggarwal (Ca)-Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 20-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 13/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By The Revenue For Assessment Year (Ay) 2011- 12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 27-05-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S. 147 Of The Act On 29-12-2018. The Revenue Is Aggrieved By Deletion Of Twin Quantum Additions Of Rs.40.85 Lacs & Rs.707.75 Lacs As Made By Ld. Ao In The Assessment Order. The Grounds Of Appeal Read As Under: -

For Appellant: Sh. Manav Bansal (CIT) – Ld. DRFor Respondent: Sh. Parikshit Aggarwal (CA)-Ld. AR
Section 131oSection 143(3)Section 148Section 40A(3)Section 68Section 68o

initiation, continuation as well as completion of the impugned assessment u/s 148 r.w.s. 147 was void-ab-initio and more-so when the reasons recorded were legally unsustainable and di not establish any valid ‘reason to believe; of escapement of income and also when no addition was made on issue

Krishna Prabhas Agro Oils Private Limited, Maredubaka vs. Assisstant Commissioner of Income Tax, Kakinada

In the result, we herein, in terms of our aforesaid observations, set aside the CIT(A) order and vacate the addition of Rs

ITA 546/VIZ/2025[2017-2018]Status: DisposedITAT Visakhapatnam12 Nov 2025AY 2017-2018

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.546/Viz/2025 ("नधा"रण वष"/Assessment Year: 2017-18) Krishna Prabhas Agro Oils Vs. Assistant Commissioner Private Limited, Of Income Tax, Maredubaka, Kakinada. Kakinada. Pan: Aaics2638B (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Mrs. Hema Latha. K, Ca (Hybrid Hearing) राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 10/11/2025 Hearing: घोषणा क" तार"ख/Date Of 12/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

For Appellant: Mrs. Hema Latha. K, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(1)Section 147Section 148Section 250Section 68

invalid, as the same was made on mere suspicion and surmises. 3. The Ld. CIT(A) ought to have appreciated that as per the reasons recorded for re-opening of assessment, made available to assessee vide notice dt.21-04-2021 and the Assessment order, Ld.AO had re- opened the case of assessee