Reopening Tax Assessment After 4 Years Requires Valid Reason u/s 147, Mere Suspicion Insufficient.

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....Reopening of assessment u/s 147 - assessment after 4 years - reason to suspect OR reason to believe - Reopening of assessment which is already concluded under Section 143(3) of the Act of the assessment cannot be reopened without any allegation by the Assessing Officer that there was non-disclosure of true and correct facts by the assessee while framing the original assessment. Hence, we are inclined to annul the assessment. - AT....