Assessment Reopening Valid u/s 147 for Deemed Dividends if AO Receives Tangible Information on Income Escapement.

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....Reopening of assessment u/s 147 - Deemed dividend - AO might have received aforesaid tangible information as to escapement of income chargeable to tax from records itself before it but the same is valid for invocation of provisions of Section 147 as there is no estoppel against law, more-so provisions of Section 147 are invoked within four years from the end of assessment year and proviso to Section 147 is not applicable .....