Assessment Reopening Needs Valid Reason, Not Suspicion: Section 147 Requires Legitimate Belief in Income Escape.

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....Validity of reopening of assessment - Although the AO may have entertained a suspicion that the Assessee’s income has escaped assessment, such suspicion could not form the basis of initiating proceedings u/s 147 of the Act. A reason to believe – not reason to suspect - is the precondition for exercise of jurisdiction u/s 147 of the Act - HC....