Court Sets Aside Reassessment Notice; AO Cannot Reopen u/s 147 Without New Evidence Beyond Initial Findings.

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....Reassessment u/s 147 - once the AO noticed the factum of bogus purchases and accommodation entries and in scrutiny assessment and taxed in the manner he thought was appropriate, he cannot be allowed to shift the stand by issuing notice of reopening of assessment without any further material available - mere change of opinion - notice set aside....