Reassessment Quashed: No New Material Justifying Reopening u/s 147; Prior Section 143(3) Proceedings Not Referenced.

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....Reassessment u/s 147 - reasons recorded without referring assessment u/s 143 (3) explains why the reasons for re-opening the assessment does not advert earlier proceedings particularly questionnaires issued by the AO specifically on the issue of the loan from PACL - all the material regarding the transaction with PACL was already available - no fresh tangible material - reassessment quashed....