Reopening assessments u/s 147 can't be justified by new reasons introduced via affidavits or oral submissions in court.

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....Reopening of assessment u/s 147 - The reasons recorded cannot be supplemented by the time the matter reaches the Court by filing of any affidavit or making any oral submission. In the premises, it is not open to the revenue to seek to sustain the re-opening notice on a new reason, namely, dis-allowance of deduction of expenditure since the whole activity was illegal.....