Income Tax Assessment Reopened u/s 147 Deemed Legally Flawed Due to Non-Compliance with Statutory Requirements.

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....Reopening of assessment u/s 147 - reply to the audit objections - in fact AO applied his mind to the audit party objection and formed a clear opinion that there is no justification for reopening of the assessment and yet it is only on the insistence of the Addl. CIT Audit that the AO changed his opinion and decided to reopen the assessment - the reopening of the assessment was vitiated in law as it did not satisfy the legal requirement of Section 147....