Reopening of assessment u/s 147 - reasonable belief - AO has...

Reopening of assessment u/s 147 - reasonable belief - AO has observed that in the data-base of the Income Tax Department, these seven companies are branded as accommodation providers. How these sweeping statements could help the ld. Assessing Officer to doubt the case of the assessee. It is not ascertainable when this data-base was prepared, what is the foundation of the data-base, whether any opportunity to contest, such an observation has been granted or not, not only to the assessee but to those companies, who have been branded as an entry provider - whatever information has been referred by the ld. Assessing Officer, it is vague and incomplete - AT