Assessment Reopening u/s 147 Needs Further Investigation for Validity; Jurisdiction Without It Is Unfounded.

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....Reopening of assessment u/s 147 - - reopening based on report of the Investigation Wing - Assessing officer can rely on the report of DIT, Investigation Wing but at the same time, where he is assuming jurisdiction u/s 147, he is required to carry out further examination and analysis in order to establish the nexus between the material and formation of belief that income has escaped assessment and in absence thereof, the assumption of jurisdiction u/s 147 has no legal basis and resultant reassessment proceedings deserve to be set-aside....