Validity of reopening of assessment u/s 147 - beyond 4 years but...

Validity of reopening of assessment u/s 147 - beyond 4 years but within 6 years - Report of the investigation wing might constitute tangible material. The decision to reopen a case on the basis of report of the investigation wing cannot always be condemned or dubbed as fishing and roving inquiry. The expression reasons to believe appearing in section 147 suggest that if the Ld. AO acts as a reasonable and prudent man on the basis of information secured by him that there is a case of reopening, then section 147 can well be pressed into service and assessment can be reopen - AT