Assessment Reopening u/s 147 Challenged: Notice Issued Late, Lacks Material Evidence of Income Escapement.

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....Reopening of assessment u/s 147 - notice for reopening is issued beyond a period of 4 years - There is no tangible material for the respondent to come to the conclusion that there is escapment of income from assessment. Moreover, there is no live link for formation of such belief while recording the reasons for reopening the assessment. - HC....