Assessment Reopening u/s 147 Invalid Without New Evidence; AO Failed to Identify Concealed Material Initially.

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....Reopening of assessment u/s 147 - validity of reasons to believe - Information has to be such as is contemplated in the Explanation 1 to section 147 of the Act. In the present case, there is no observation of the AO that the material on record was embedded in such a manner that it was not possible for the AO to notice the same at the time of scrutiny assessment.....