Re-assessment Invalid if Based Only on Audit Objections Without Independent AO Judgment, No "Reason to Believe" Found u/s 147.

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....Reopening of assessment - No re-assessment proceedings can be opened based on the Audit objections sans application of mind. It is manifest that the AO had no ‘reason to believe’, any escapement of income to assessment. Hence, assumption of jurisdiction by the AO to invoke section 147 is unjustifiable.....