Reopening Tax Assessment Requires New Evidence Even Within Four Years; Mere Belief Insufficient u/s 147.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment before expiry of 4 years - no sufficient reason to believe - Merely because reopening of assessment was before expiry of four years from the end of the relevant assessment year, that by itself will not give licence to the AO to exercise his powers u/s 147 with impunity even in the absence or lack of fresh tangible material coming to his possession - AT....