Reopening of assessment u/s 147 - reasons recorded on incorrect...

Reopening of assessment u/s 147 - reasons recorded on incorrect assumption of facts and non application of mind - possession of ITS information that the assessee has received certain amount could be basis for making further enquiries and in absence of such enquiries being conducted prior to recording of the reasons, there is absence of tangible material in possession of the Assessing officer at the time of recording of reasons and subsequent enquiries after recording of the reasons could not be used to supplement the reasons so recorded by the AO. - AT