Section 147 Reopening: AO Cannot Exceed Initial Reasons for Assessment; Vague, Irrelevant Beliefs Not Allowed.

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....Reopening of assessment u/s 147 - It is a settled principle of law that the AO cannot justify by taking recourse to some material and information beyond the scope of the reasons recorded by the Assessing Officer prior to reopening. In the instant case, the respondent has traveled beyond the scope of reasons recorded in order to justify the action of reopening. - the formation of belief entertained by the Assessing Officer seems to be vague and based on irrelevant material. - HC....