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Assessment Reopening u/s 147 Invalid Without AO Verification; Insufficient Grounds Without Relevant Documents from Authorities.
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....Reopening of assessment u/s 147 - Mere intimation received from any authority cannot lead to immediate presumption but it needs to be verified by the AO and to apply his mind. Here in this case, even the documents pertaining to Custom & Central Excise Authorities was not available with the AO at the time of initiation of proceedings which fact has been surfaced before us. Thus, we hold that the reasons recorded by the AO do not give jurisdiction to reopen the assessment u/s 147 read with section 148. - AT....